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).

EXHIBIT D

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October 3, 2011

Via E-Mail ([e-mail])
Rachel Herrick Kassabian
Quinn Emmanuel
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, CA 94065-2139
Re:

Apple v. Samsung, Case No. 11-cv-1846-LHK (N.D. Cal.)

Dear Rachel:
As you know, over the past two weeks Apple has provided Samsung with a series of dates
for prosecutor and inventor depositions. I thought it would make sense to confirm the
schedule of all of the inventor and prosecutor dates confirmed by Apple to date. Note that
this includes new design inventors — Freddy Anzures, Duncan Kerr, and Peter RussellClarke — that were the subject of an email from me earlier tonight.
Date
September 30, 2011
September 30, 2011
October 3, 2011
October 3, 2011
October 4, 2011
October 5, 2011
October 5, 2011
October 5, 2011
October 6, 2011
October 6, 2011
October 7, 2011
October 7, 2011
October 10, 2011
October 10, 2011
October 12, 2011
October 12, 2011

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Deponent’s Last
Name
Allen
Szepesi
Schweigert
Xie
Scheller
Williams
Beyers
Peloquin
Mallie
Wong
Durkin
Rossin
Kubota
Weaver
Chartove
Williamson

Type
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Prosecutor
Utility Inventor

When Apple Offered
Date to Samsung
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 21, 2011
September 22, 2011

Rachel Herrick Kassabian
October 3, 2011
Page Two
Date
October 12, 2011
October 13, 2011
October 14, 2011
October 14, 2011
October 14, 2011
October 14, 2011
October 18, 2011
October 18, 2011
October 18, 2011
October 18, 2011
October 19, 2011
October 19, 2011
October 20, 2011
October 20, 2011
October 25, 2011
October 25, 2011
October 26, 2011
October 26, 2011
October 26, 2011
October 26, 2011
October 27, 2011

Deponent’s Last
Name
McNight
Elias
Blumenberg
Herz
Lemay
Chaudhri
Huppi
Platzer
Christie
Anzures
Ording
Hotelling
Land
Strickon
Hoellwarth
Russell-Clarke
Boule
Christensen
Van Os
Kerr
Forstall

Type
Prosecutor
Utility Inventor
Utility Inventor
Utility Inventor
Utility Inventor
Utility Inventor
Utility Inventor
Utility Inventor
Utility Inventor
Design Inventor
Utility Inventor
Utility Inventor
Utility Inventor
Utility Inventor
Prosecutor
Design Inventor
Utility Inventor
Utility Inventor
Utility Inventor
Design Inventor
Utility Inventor

When Apple Offered
Date to Samsung
September 21, 2011
September 22, 2011
September 30, 2011
September 27, 2011
September 22, 2011
September 22, 2011
September 27, 2011
September 22, 2011
September 30, 2011
October 3, 2011
September 22, 2011
September 30, 2011
September 30, 2011
September 27, 2011
September 30, 2011
October 3, 2011
September 30, 2011
September 30, 2011
September 30, 2011
October 3, 2011
September 30, 2011

As discussed in previous meet-and-confer communications, we will continue sending
confirmed dates as soon as we have them, and expect by the end of the week to have dates
for all remaining witnesses who are current employees or jointly represented. Also as
discussed in previous meet-and-confer communication, Apple intends to complete its
production of documents for each deponent no later than five days before his or her
deposition.
Sincerely,
/s/ Matthew I. Kreeger
Matthew I. Kreeger
cc: Victoria Maroulis, Esq.

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