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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1 2 3 4 5 6 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 7 8 9 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN JOSE DIVISION 13 15 16 17 18 19 20 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 10 14 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. 21 22 23 24 25 26 27 28 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 1 I, Jason Bartlett, declare as follows: 2 1. I am a partner in the law firm of Morrison & Foerster LLP, counsel for Apple Inc. 3 (“Apple”) in its suit against Samsung Electronics Co., Ltd., Samsung Electronics America, Inc. 4 and Samsung Telecommunications America, LLC (collectively, “Samsung”). Unless otherwise 5 indicated, I have personal knowledge of the matters set forth below. If called as a witness I could 6 and would testify competently as follows: 7 8 9 10 11 12 13 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. 3. 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. 4. 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. 5. Attached hereto as Exhibit D to this Declaration is a true and correct copy of a 14 letter that was transmitted by counsel for Apple to counsel for Samsung on October 3, 2011. I am 15 informed and believe that this letter accurately summarizes meet-and-confer communications that 16 took place between September 22 and October 1, 2011. 17 18 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. 19 20 /s/ Jason R. Bartlett Jason R. Bartlett 21 22 23 24 25 26 27 28 sf-3052839 1 ATTESTATION OF E-FILED SIGNATURE 2 I, Michael A. Jacobs , 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 Jason R. Bartlett has 4 concurred in this filing. 5 Dated: October 4, 2011 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 sf-3052839 /s/ Michael A. Jacobs Michael A. Jacobs

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