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

Filing 290

AMENDED DECLARATION of Jason R. Bartlett in Support of 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)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
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: [phone]
Facsimile: [phone]
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: [phone]
Facsimile: [phone]

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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Case No.

11-cv-01846-LHK

AMENDED 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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AMENDED BARTLETT DECL. ISO APPLE OPPO. TO MOTION TO COMPEL DEPO SCHEDULING
CASE NO. 11-CV-01846-LHK
sf-3053355

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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.
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.
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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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AMENDED BARTLETT DECL. ISO APPLE OPPO. TO MOTION TO COMPEL DEPO SCHEDULING
CASE NO. 11-CV-01846-LHK
sf-3053355

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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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/s/ Michael A. Jacobs
Michael A. Jacobs

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AMENDED BARTLETT DECL. ISO APPLE OPPO. TO MOTION TO COMPEL DEPO SCHEDULING
CASE NO. 11-CV-01846-LHK
sf-3053355