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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EXHIBIT D 425 MARKET STREET SAN FRANCISCO CALIFORNIA 94105-2482 TELEPHONE: 415.268.7000 FACSIMILE: 415.268.7522 MO RRI SO N & F O E RST E R L LP N E W YO RK , SAN F RAN C I SCO , L O S A N G E L E S, P A L O A L T O , SAC RAME N T O , SAN D I E G O , D E N VE R, N O RT H E RN VI RG I N I A, WASH I N G T O N , D .C. T O K YO , L O N D O N , BR U SSE L S, BE I JI N G , SH AN G H AI , H O N G K O N G WWW.MOFO.COM Writer’s Direct Contact 415.268.6467 MKreeger@mofo.com October 3, 2011 Via E-Mail (rachelkassabian@quinnemanuel.com) 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 sf-3053305 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. sf-3053305

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