Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
217
Letter from Richard Hung to Magistrate Judge Paul Singh Grewal. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H)(Bartlett, Jason) (Filed on 9/12/2011)
Exhibit C
RE: Apple v. Samsung -- Proposed Schedule for Preliminary Injunction Motion
Page 1 of 2
Bartlett, Jason R.
From:
Victoria Maroulis [victoriamaroulis@quinnemanuel.com]
Sent:
Thursday, July 21, 2011 10:12 AM
To:
Bartlett, Jason R.; Todd Briggs; Sara Jenkins; Erik Olson
Cc:
Ahn, Deok Keun Matthew; Hung, Richard S. J.; Jacobs, Michael A.; McElhinny, Harold J.; Monach,
Andrew E.; Taylor, Jennifer Lee (SF)
Subject: RE: Apple v. Samsung: designation of 30(b)(6) topics for Lutton and Twiggs
Thanks, Jason. On other deposition logistics:
1. We are making arrangements to start the Twiggs deposition at 10 am on Wednesday per
witness’s request; the deposition will take place in our Silicon Valley office and the notice will be
sent later today;
2. We are making arrangements to start the Lutton deposition at 9 am on Tuesday; we understand
that you are trying to reach the witness to confirm the start time so please let us know as soon
as you hear from him if that time needs to be adjusted. Because Mr. Lutton is covering a
number of topics, we are technically entitled to depose him for 7 hours in personal capacity and
7 hours as a 30(b)(6) deponent. We do not anticipate needing this much time but would
appreciate it if you provided Mr. Lutton heads up that his deposition may go for longer than the
usual 7 hours and may need to be resumed the next day.
3. Per our agreement, we understand that you will be producing documents relevant to those two
witnesses no later than Saturday and Sunday respectively. To the extent possible, we will
appreciate a production on Friday. If that is not possible, please designate a member of your
team with whom someone on our team can communicate directly about weekend deliveries.
From: Bartlett, Jason R. [mailto:JasonBartlett@mofo.com]
Sent: Wednesday, July 20, 2011 10:50 PM
To: Victoria Maroulis; Todd Briggs; Sara Jenkins
Cc: Ahn, Deok Keun Matthew; Hung, Richard S. J.; Jacobs, Michael A.; McElhinny, Harold J.; Monach,
Andrew E.; Taylor, Jennifer Lee (SF)
Subject: RE: Apple v. Samsung: designation of 30(b)(6) topics for Lutton and Twiggs
Dear Vicki,
Here is our current plan with respect to Lutton and Twiggs:
Lutton will cover 5, 7-10, and aspects of 11 to the extent covered in his declaration, as well as
market share loss.
Twiggs will cover the aspects of 11 that are addressed in her declaration.
Jason
From: Victoria Maroulis [mailto:victoriamaroulis@quinnemanuel.com]
Sent: Wednesday, July 20, 2011 11:47 AM
To: Bartlett, Jason R.; Todd Briggs; Sara Jenkins
Cc: Ahn, Deok Keun Matthew; Hung, Richard S. J.
Subject: Apple v. Samsung: designation of 30(b)(6) topics for Lutton and Twiggs
Dear Jason,
We understand that Apple plans to distribute some of its 30(b)(6) topics among the current deponents.
9/12/2011
RE: Apple v. Samsung -- Proposed Schedule for Preliminary Injunction Motion
Page 2 of 2
Please let us know today whether Mr. Lutton and Ms. Twiggs will be given any of the 30(b)(6) topics so that we can
prepare accordingly.
Thank you.
Victoria Maroulis
Partner,
Quinn Emanuel Urquhart & Sullivan, LLP
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, CA 94065
650-801-5022 Direct
650.801.5000 Main Office Number
650.801.5100 FAX
victoriamaroulis@quinnemanuel.com
www.quinnemanuel.com
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9/12/2011
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