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

Filing 309

Declaration of Jennifer Lee Taylor n Support of Apple's Objections to Samsung's Untimely Evidence, filed by Apple Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8)(Jacobs, Michael) (Filed on 10/17/2011) Modified on 10/18/2011. Cannot link entry. Objections have not been efiled (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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WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (CA SBN 244180)
[e-mail]
WILMER CUTLER PICKERING HALE
AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

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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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APPLE INC., a California corporation,

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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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DECL. OF JENNIFER LEE TAYLOR ISO APPLE’S OBJECTIONS
CASE NO. 11-cv-01846-LHK
sf-3059419

Case No.

11-cv-01846-LHK

DECLARATION OF JENNIFER
LEE TAYLOR IN SUPPORT OF
APPLE’S OBJECTIONS TO
SAMSUNG’S UNTIMELY NEW
EVIDENCE

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I, Jennifer Lee Taylor, declare as follows:

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1.

I am an attorney at the law firm of Morrison & Foerster LLP, counsel of record in

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this action for plaintiff Apple Inc. (“Apple”). I submit this declaration in support of Apple’s

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Objections to Samsung’s Untimely New Evidence. Unless otherwise indicated, I have personal

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knowledge of the matters set forth below. If called as a witness I could and would testify

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competently as follows.

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1.

Attached hereto as Exhibit 1 is a true and correct copy of a photograph that I took

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of a blank sheet of white Plexiglas that was later marked as Ex. 267 at the deposition of Roger

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Fidler. The Plexiglas sheet was adjacent to a piece of paper when I took the photograph.

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2.

Attached hereto as Exhibit 2 is a true and correct copy of a photograph that I took

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of a stack of blank white Plexiglas sheets, one of which was later marked as Ex. 267 at the

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deposition of Roger Fidler.

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3.

Attached hereto as Exhibit 3 is a true and correct copy of a photograph that I took

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of a Plexiglas digital newspaper mock-up that was marked as Ex. 268 at the deposition of Roger

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Fidler. We have added markings to indicate the edge of the newssheet encased in the Plexiglas,

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the location of the raised frame, and the edge of the raised frame.

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4.

Attached hereto as Exhibit 4 is a true and correct copy of a photograph that I took

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of a Plexiglas digital newspaper mock-up that was marked as Ex. 269 at the deposition of Roger

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Fidler. We have added markings to indicate the edge of the newssheet encased in the Plexiglas,

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the location of the raised frame, and the edge of the raised frame.

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5.

Attached hereto as Exhibit 5 is a true and correct copy of a photograph that I took

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of the outside edge and corner of a Plexiglas digital newspaper mock-up that was marked as

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Ex. 269 at the deposition of Roger Fidler. The Plexiglas digital newspaper mock-up was adjacent

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to a laptop computer when I took the photograph.

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6.

Attached hereto as Exhibit 6 is a true and correct copy of a photograph that I took

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of part of the front surface and a corner of the Plexiglas digital newspaper mock-up that was

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marked as Ex. 269 at the deposition of Roger Fidler. We have added markings to indicate the

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location and edge of the raised frame.
DECL. OF JENNIFER LEE TAYLOR ISO APPLE’S OBJECTIONS
CASE NO. 11-cv-01846-LHK
sf-3059419

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7.

Attached hereto as Exhibit 7 is a true and correct copy of a photograph that I took

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of the back of the Plexiglas digital newspaper mock-up that was marked as Ex. 268 at the

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deposition of Roger Fidler. We have added markings to indicate the edge of the newssheet

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encased in the Plexiglas.

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8.

Attached hereto as Exhibit 8 is a true and correct copy of a photograph that I took

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of the back of the Plexiglas digital newspaper mock-up that was marked as Ex. 268 at the

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deposition of Roger Fidler.

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9.

I took each of the above-described photographs on September 23, 2011, at the

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deposition of Roger Fidler. Apple is submitting these photographs on a contingent basis in the

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event that the Court decides to consider Samsung’s photographs of Exhibits 267-269 from the

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deposition of Roger Fidler.

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I declare under the penalty of perjury that the foregoing is true and correct and that this
Declaration was executed this 17th day of October, 2011, at San Francisco, California.

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By:

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/s/ Jennifer Lee Taylor
Jennifer Lee Taylor

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DECL. OF JENNIFER LEE TAYLOR ISO APPLE’S OBJECTIONS
CASE NO. 11-cv-01846-LHK
sf-3059419

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ATTESTATION OF E-FILED SIGNATURE
I, MICHAEL A. JACOBS, am the ECF User whose ID and password are being used to

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file this Declaration. In compliance with General Order 45, X.B., I hereby attest that Jennifer Lee

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Taylor has concurred in this filing.

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Dated: October 17, 2011

By:

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/s/ Michael A. Jacobs
Michael A. Jacobs

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DECL. OF JENNIFER LEE TAYLOR ISO APPLE’S OBJECTIONS
CASE NO. 11-cv-01846-LHK
sf-3059419

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