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

Filing 322

STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE FOR DEPOSITIONS OF INVENTORS OF APPLE'S PATENTS by Apple Inc., Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Declaration Melissa N. Chan In Support Of, #2 Declaration Teresa N. Burlison In Support Of)(Maroulis, Victoria) (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]
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,
Plaintiff,

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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,

Case No.

11-cv-01846-LHK

DECLARATION OF TERESA N.
BURLISON IN SUPPORT OF
STIPULATION AND
[PROPOSED] ORDER
EXTENDING DEADLINE FOR
DEPOSITIONS OF INVENTORS
OF APPLE’S PATENTS
PURSUANT TO CIVIL L.R. 62(A)
Trial Date: July 30, 2012

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Defendants.
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02198.51855/4404483.1 DECL. OF T. BURLISON ISO STIPULATION AND [PROPOSED] ORDER

CASE NO. 11-cv-01846-LHK
pa-1492261

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I, Teresa N. Burlison, declare as follows:

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1.

I am an associate 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 the parties’

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stipulation and proposed order extending the deadline for the depositions of several of the

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inventors of Apple’s patents, pursuant to Civil L.R. 6-2. Unless otherwise indicated, I have

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

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testify competently as follows.
2.

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On August 24, 2011, the Court granted an expedited trial schedule as to Apple’s

claims and Samsung’s counterclaims.
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On August 25, 2011, the Court entered a Minute Order and Case Management

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Order (“Order”). See Docket No. 187. The Court ordered that the depositions of the inventors

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and prosecuting attorneys for Apple’s patents must be completed by November 1, 2011.
4.

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Since the Court’s Order, Apple has worked in good faith with Samsung to

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schedule the depositions of its inventors and prosecuting attorneys. Despite the parties’ best

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efforts, however, they have not been able to schedule the depositions of inventors Jonathan Ive,

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Douglas Satzger, Shin Nishibori, and Christopher Stringer before November 1, 2011.
5.

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Mr. Satzger is a former Apple employee represented by separate counsel. He is

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unable to sit for deposition before November 1 because, during the month of October, his lawyer

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has a full deposition schedule in a separate class action matter.
6.

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Mr. Nishibori is unable to sit for deposition before November 1 because he

currently is on a voluntary leave of absence from Apple.

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7.

Mr. Ive is unable to sit for deposition before November 1 for personal reasons.

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8.

Mr. Stringer is unable to sit for deposition before November 1 because of work

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and scheduling conflicts.
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The parties have not previously modified the Court’s August 25, 2011 Order, and

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the requested modification should not have any effect on the remainder of the schedule for this

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case.

DECL. OF T. BURLISON ISO STIPULATION AND [PROPOSED] ORDER
CASE NO. 11-cv-01846-LHK
pa-1492261

02198.51855/4404483.1

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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 Palo Alto, California.

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By:

/s/ Teresa N. Burlison
Teresa N. Burlison

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General Order 45 Attestation
I, Victoria F. Maroulis, am the ECF user whose ID and password are being used to file
this Declaration. In compliance with General Order 45(X)(B), I hereby attest that Teresa N.
Burlison has concurred in this filing.

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/s/ Victoria Maroulis

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02198.51855/4404483.1 DECL. OF T. BURLISON ISO STIPULATION AND [PROPOSED] ORDER

CASE NO. 11-cv-01846-LHK
pa-1492261

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