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

Filing 319

MOTION to Compel Apple's Motion to Compel SamSung to Produce Documents and Provide Responsive Answers to Propounded Discovery filed by Apple Inc.. Motion Hearing set for 10/25/2011 10:00 AM in Courtroom 5, 4th Floor, San Jose before Magistrate Judge Paul Singh Grewal. Responses due by 10/4/2011. Replies due by 10/11/2011. (Attachments: #1 Proposed Order)(Bartlett, Jason) (Filed on 10/18/2011)

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
JENNIFER LEE TAYLOR (CA SBN 161368)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
Attorneys for Plaintiff
APPLE INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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APPLE INC., a California corporation,

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Case No.

Plaintiff,
v.
SAMSUNG ELECTRONICS CO., LTD., A
Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New York
corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC, a
Delaware limited liability company,

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4:11-cv-01846-LB

[PROPOSED] ORDER GRANTING
APPLE’S MOTION TO COMPEL
SAMSUNG TO PRODUCE
DOCUMENTS AND PROVIDE
RESPONSIVE ANSWERS TO
PROPOUNDED DISCOVERY
Date: October 25, 2011
Time: 10:00 a.m.
Courtroom: 5, 4th Floor
Judge: Hon. Paul S. Grewal

Defendants.
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[PROPOSED] ORDER GRANTING MOTION TO COMPEL
la-1141310

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Plaintiff Apple Inc. (“Apple”) has moved pursuant to Civil Local Rule 37 for an order

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compelling Defendants Samsung Electronics Co., Ltd, Samsung Electronics America, Inc., and

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Samsung Telecommunications America, LLC (collectively, “Samsung”) to produce all

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documents and things responsive to various Apple Requests for Production. Apple also seeks an

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order compelling Samsung to produce a witness to testify to the subject matter of these various

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requests as well to Samsung’s efforts to fulfill its discovery obligations with respect to these

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requests.

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Having considered the arguments of the parties and the papers submitted, and finding
good cause therefore, the Court hereby GRANTS Apple’s Motion to Compel Samsung to

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Produce Documents and Provide Responsive Answers to Propounded Discovery, and ORDERS

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the following:

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That by no later than September 27, 2011, Samsung shall produce to Apple all non-

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privileged documents within its possession, custody, or control responsive to each of Apples

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Requests for Production Nos. 1, 166, 206, 214, and 215;

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That counsel for Samsung shall set forth in a certified statement accompanying its

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September 27 production that the obligations of discovery have been met by Samsung as to all

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documents, including those in Korea; and

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That Samsung shall make available by no later than September 29, 2011, a witness

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prepared to testify as to the subject matter of the aforementioned Requests for Production and as

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to the efforts Samsung made to satisfy its discovery obligations pursuant to this Order.

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IT IS SO ORDERED.

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Dated: ___________________, 2011

By:
Honorable Paul S. Grewal, U.S.M.J.

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[PROPOSED] ORDER GRANTING MOTION TO COMPEL
la-1141310