Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
289
DECLARATION of Jason R. Bartlett in Opposition to #283 MOTION to Compel Apple to Schedule Inventor Depositions and Prosecuting Attorney Depositions, filed by Apple Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Related document(s) #283 ) (Jacobs, Michael) (Filed on 10/4/2011) Modified text on 10/5/2011 (dhm, COURT STAFF).
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HAROLD J. MCELHINNY (CA SBN 66781)
HMcElhinny@mofo.com
MICHAEL A. JACOBS (CA SBN 111664)
MJacobs@mofo.com
RICHARD S.J. HUNG (CA SBN 197425)
RHung@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: 415.268.7000
Facsimile: 415.268.7522
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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WILLIAM F. LEE (pro hac vice)
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: (617) 526-6000
Facsimile: (617) 526-5000
Attorneys for Plaintiff
APPLE INC
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MARK D. SELWYN (CA SBN 224180)
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: (650) 858-600
Facsimile: (650) 858-6100
APPLE INC., a California Corporation,
Plaintiff,
v.
SAMSUNG ELECTRONICS CO., LTD., a
Korean corporation; SAMSUNG
ELECTRONICS AMERICA, INC., a New
York corporation; and SAMSUNG
TELECOMMUNICATIONS AMERICA
LLC, a Delaware limited liability company,
Defendants.
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sf-3052839
Case No.
11-cv-01846-LHK
DECLARATION OF JASON R.
BARTLETT IN SUPPORT OF
APPLE’S OPPOSITION TO
MOTION TO COMPEL APPLE TO
SCHEDULE INVENTOR AND
PROSECUTING ATTORNEY
DEPOSITIONS
Date:
Time:
Place:
Judge:
October 4, 2011
5:00 P.M.
Telephonic Hearing
Hon. Paul S. Grewal
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I, Jason Bartlett, declare as follows:
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1.
I am a partner in the law firm of Morrison & Foerster LLP, counsel for Apple Inc.
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(“Apple”) in its suit against Samsung Electronics Co., Ltd., Samsung Electronics America, Inc.
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and Samsung Telecommunications America, LLC (collectively, “Samsung”). Unless otherwise
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indicated, I have personal knowledge of the matters set forth below. If called as a witness I could
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and would testify competently as follows:
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2.
Attached hereto as Exhibit A to this Declaration is a true and correct copy of the
transcript of proceedings in the courtroom of the Honorable Lucy Koh on August 24, 2011.
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Attached hereto as Exhibit B to this Declaration is a true and correct copy of a
letter that was transmitted by counsel for Apple to counsel for Samsung on September 14, 2011.
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Attached hereto as Exhibit C to this Declaration is a true and correct copy of a
letter that was transmitted by counsel for Apple to counsel for Samsung on October 3, 2011.
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Attached hereto as Exhibit D to this Declaration is a true and correct copy of a
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letter that was transmitted by counsel for Apple to counsel for Samsung on October 3, 2011. I am
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informed and believe that this letter accurately summarizes meet-and-confer communications that
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took place between September 22 and October 1, 2011.
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I declare under the penalty of perjury that the forgoing is true and correct. Executed this
4th day of October, 2011, at San Francisco, California.
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/s/ Jason R. Bartlett
Jason R. Bartlett
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sf-3052839
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ATTESTATION OF E-FILED SIGNATURE
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I, Michael A. Jacobs , am the ECF User whose ID and password are being used to file this
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Declaration. In compliance with General Order 45, X.B., I hereby attest that Jason R. Bartlett has
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concurred in this filing.
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Dated: October 4, 2011
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sf-3052839
/s/ Michael A. Jacobs
Michael A. Jacobs
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