Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1541

OBJECTIONS to Samsung's (1) Objections Regarding Forstall Exhibits, and Amended Exhibit Disclosures for Bresller, Kare, Schiller and Denison, and (2) Responses Regarding Exhibits for Denison Direct Exam and Schiller Cross Exam by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: # 1 Declaration of Ketan V. Patel, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I)(Maroulis, Victoria) (Filed on 8/2/2012)

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1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Charles K. Verhoeven (Bar No. 170151)  charlesverhoeven@quinnemanuel.com 50 California Street, 22nd Floor  San Francisco, California 94111 Telephone: (415) 875-6600  Facsimile: (415) 875-6700  Kevin P.B. Johnson (Bar No. 177129) kevinjohnson@quinnemanuel.com  Victoria F. Maroulis (Bar No. 202603) victoriamaroulis@quinnemanuel.com th  555 Twin Dolphin Drive, 5 Floor Redwood Shores, California 94065-2139  Telephone: (650) 801-5000 Facsimile: (650) 801-5100  Michael T. Zeller (Bar No. 196417)  michaelzeller@quinnemanuel.com 865 S. Figueroa St., 10th Floor  Los Angeles, California 90017 Telephone: (213) 443-3000  Facsimile: (213) 443-3100  Attorneys for SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA,  INC. and SAMSUNG TELECOMMUNICATIONS AMERICA, LLC   UNITED STATES DISTRICT COURT  NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION   APPLE INC., a California corporation, CASE NO. 11-cv-01846-LHK  DECLARATION OF KETAN V. PATEL IN SUPPORT OF SAMSUNG’S (1) OBJECTIONS REGARDING FORSTALL EXHIBITS, AND AMENDED EXHIBIT DISCLOSURES FOR BRESSLER, KARE, SCHILLER AND DENISON, AND (2) RESPONSES REGARDING EXHIBITS FOR DENISON DIRECT EXAM AND SCHILLER CROSS EXAM  Plaintiff, vs.  SAMSUNG ELECTRONICS CO., LTD., a Korean business entity; SAMSUNG  ELECTRONICS AMERICA, INC., a New York corporation; SAMSUNG  TELECOMMUNICATIONS AMERICA, LLC, a Delaware limited liability company,  Defendants.    02198.51845/4887926.1 Case No. 11-cv-01846-LHK DECLARATION OF KETAN V. PATEL IN SUPPORT OF SAMSUNG’S OBJECTIONS AND RESPONSES 1 DECLARATION OF KETAN V. PATEL 2 I, KETAN V. PATEL, do hereby declare as follows: 3 1. I am an associate with Quinn Emanuel Urquhart & Sullivan, LLP, counsel for 4 Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung 5 Telecommunications America, LLC (collectively, “Samsung”). I submit this declaration in 6 support of Samsung’s Objections to Apple’s Proposed Examination Exhibits and Materials for 7 Third Day of Trial. I have personal knowledge of the facts set forth in this declaration and, if 8 called as a witness, could and would competently testify to them under oath. 9 2. Attached as Exhibit A is a true and correct copy of Apple Inc.’s Initial Disclosures 10 Pursuant to Rule 26(A)(1) served on August 26, 2011. 11 3. Attached as Exhibit B is a true and correct copy of Apple Inc.’s First Amended and 12 Supplemental Initial Disclosures Pursuant to Rule 26(A)(1) served on March 4, 2012. 13 4. Attached as Exhibit C is a true and correct copy of Apple’s Revised Deposition 14 Designation List (Exhibit 3 to Joint Pretrial Conference Statement) served on July 23, 2012. 15 5. Attached as Exhibit D is a true and correct excerpt from the Oct. 27, 2011 16 deposition of Scott Forstall. 17 6. Attached as Exhibit E is a true and correct excerpt from the Feb. 9, 2012 18 Deposition of Scott Forstall. 19 7. Attached as Exhibit F are true and correct excerpts from Apple Inc.’s Objections 20 and Responses to Samsung Electronics Co. Ltd.’s First Set of Interrogatories to Apple Inc., Apple 21 Inc.’s Second Amended Objections and Response to Samsung’s Interrogatory No. 1 to Apple, 22 Apple Inc.’s Third Amended Objections and Response to Samsung’s Interrogatory No. to Apple, 23 Apple Inc.’s Fourth Amended Objections and Response to Samsung’s Interrogatory No. 1 to 24 Apple, Apple Inc.’s Fifth Amended Objections and Response to Samsung’s Interrogatory No. 1 to 25 Apple and Apple Inc.’s Amended Objections and Response to Samsung’s Interrogatory No. 1 to 26 Apple. 27 28 02198.51845/4887926.1 Case No. 11-cv-01846-LHK -2DECLARATION OF KETAN V. PATEL IN SUPPORT OF SAMSUNG’S OBJECTIONS AND RESPONSES 1 8. Attached as Exhibit G are true and correct copies of pages 20 and 21 from 2 Samsung’s Objections to Apple’s Notice of Rule 30(B)(6) Deposition of Samsung Electronics 3 Co., Ltd Relating to Apple’s Motion for a Preliminary Injunction. 4 9. Attached as Exhibit H are true and correct copies of pages 6 through 9 of Apple 5 Inc.'s Corrected Amended Objections and Responses to Samsung Electronics Co. Ltd.’s 6 Interrogatory Nos. 4, 6, 7, 16, 17, 18 to Apple, Inc. The relevant passages are at 6:5-10 and 9:117 26. 8 10. Attached as Exhibit I are true and correct copies of two email exchanges between 9 Victoria Maroulis and Taryn Rawson dated August 1, 2012 in which Samsung requested that 10 Apple identify what the alleged “related theories” were that Samsung failed to disclose, but Apple 11 refused to do so. 12 13 I declare under penalty of perjury that the forgoing is true and correct to the best of my 14 knowledge. 15 Executed this 2nd day of August, 2012, in San Jose, CA. 16 17 18 /s/ Ketan V. Patel KETAN V. PATEL 19 20 21 22 23 24 25 26 27 28 02198.51845/4887926.1 Case No. 11-cv-01846-LHK -3DECLARATION OF KETAN V. PATEL IN SUPPORT OF SAMSUNG’S OBJECTIONS AND RESPONSES 1 General Order 45 Attestation 2 I, Victoria F. Maroulis, am the ECF user whose ID and password are being used to file this 3 Declaration. In compliance with General Order 45(X)(B), I hereby attest that KETAN V. PATEL 4 has concurred in this filing. 5 6 DATE: August 2, 2012 /s/ Victoria Maroulis Victoria Maroulis 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 02198.51845/4887926.1 Case No. 11-cv-01846-LHK -4DECLARATION OF KETAN V. PATEL IN SUPPORT OF SAMSUNG’S OBJECTIONS AND RESPONSES

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