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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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 WILLIAM F. LEE william.lee@wilmerhale.com WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street Boston, MA 02109 Telephone: (617) 526-6000 Facsimile: (617) 526-5000 MARK D. SELWYN (CA SBN 244180) mark.selwyn@wilmerhale.com WILMER CUTLER PICKERING HALE AND DORR LLP 950 Page Mill Road Palo Alto, California 94304 Attorneys for Plaintiff and Counterclaim-Defendant APPLE INC. 10 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN JOSE DIVISION 14 15 APPLE INC., a California corporation, 16 17 18 19 20 21 22 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. 23 24 25 26 27 28 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 1 I, Jennifer Lee Taylor, declare as follows: 2 1. I am an attorney at the law firm of Morrison & Foerster LLP, counsel of record in 3 this action for plaintiff Apple Inc. (“Apple”). I submit this declaration in support of Apple’s 4 Objections to Samsung’s Untimely New Evidence. Unless otherwise indicated, I have personal 5 knowledge of the matters set forth below. If called as a witness I could and would testify 6 competently as follows. 7 1. Attached hereto as Exhibit 1 is a true and correct copy of a photograph that I took 8 of a blank sheet of white Plexiglas that was later marked as Ex. 267 at the deposition of Roger 9 Fidler. The Plexiglas sheet was adjacent to a piece of paper when I took the photograph. 10 2. Attached hereto as Exhibit 2 is a true and correct copy of a photograph that I took 11 of a stack of blank white Plexiglas sheets, one of which was later marked as Ex. 267 at the 12 deposition of Roger Fidler. 13 3. Attached hereto as Exhibit 3 is a true and correct copy of a photograph that I took 14 of a Plexiglas digital newspaper mock-up that was marked as Ex. 268 at the deposition of Roger 15 Fidler. We have added markings to indicate the edge of the newssheet encased in the Plexiglas, 16 the location of the raised frame, and the edge of the raised frame. 17 4. Attached hereto as Exhibit 4 is a true and correct copy of a photograph that I took 18 of a Plexiglas digital newspaper mock-up that was marked as Ex. 269 at the deposition of Roger 19 Fidler. We have added markings to indicate the edge of the newssheet encased in the Plexiglas, 20 the location of the raised frame, and the edge of the raised frame. 21 5. Attached hereto as Exhibit 5 is a true and correct copy of a photograph that I took 22 of the outside edge and corner of a Plexiglas digital newspaper mock-up that was marked as 23 Ex. 269 at the deposition of Roger Fidler. The Plexiglas digital newspaper mock-up was adjacent 24 to a laptop computer when I took the photograph. 25 6. Attached hereto as Exhibit 6 is a true and correct copy of a photograph that I took 26 of part of the front surface and a corner of the Plexiglas digital newspaper mock-up that was 27 marked as Ex. 269 at the deposition of Roger Fidler. We have added markings to indicate the 28 location and edge of the raised frame. DECL. OF JENNIFER LEE TAYLOR ISO APPLE’S OBJECTIONS CASE NO. 11-cv-01846-LHK sf-3059419 1 1 7. Attached hereto as Exhibit 7 is a true and correct copy of a photograph that I took 2 of the back of the Plexiglas digital newspaper mock-up that was marked as Ex. 268 at the 3 deposition of Roger Fidler. We have added markings to indicate the edge of the newssheet 4 encased in the Plexiglas. 5 8. Attached hereto as Exhibit 8 is a true and correct copy of a photograph that I took 6 of the back of the Plexiglas digital newspaper mock-up that was marked as Ex. 268 at the 7 deposition of Roger Fidler. 8 9. I took each of the above-described photographs on September 23, 2011, at the 9 deposition of Roger Fidler. Apple is submitting these photographs on a contingent basis in the 10 event that the Court decides to consider Samsung’s photographs of Exhibits 267-269 from the 11 deposition of Roger Fidler. 12 13 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. 14 15 By: 16 /s/ Jennifer Lee Taylor Jennifer Lee Taylor 17 18 19 20 21 22 23 24 25 26 27 28 DECL. OF JENNIFER LEE TAYLOR ISO APPLE’S OBJECTIONS CASE NO. 11-cv-01846-LHK sf-3059419 2 1 2 ATTESTATION OF E-FILED SIGNATURE I, MICHAEL A. JACOBS, am the ECF User whose ID and password are being used to 3 file this Declaration. In compliance with General Order 45, X.B., I hereby attest that Jennifer Lee 4 Taylor has concurred in this filing. 5 Dated: October 17, 2011 By: 6 /s/ Michael A. Jacobs Michael A. Jacobs 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECL. OF JENNIFER LEE TAYLOR ISO APPLE’S OBJECTIONS CASE NO. 11-cv-01846-LHK sf-3059419 3

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