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

Filing 463

ADMINISTRATIVE MOTION for Temporary Relief Regarding Lead Counsel Meet and Confer Requirement filed by Apple Inc.. Responses due by 12/12/2011. (Attachments: #1 Declaration, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Proposed Order)(Jacobs, Michael) (Filed on 12/8/2011) Modified text on 12/9/2011 (dhm, COURT STAFF).

Exhibit D

Subject:

Mazza, Mia
Monday, December 05, 2011 9:27 PM
'[e-mail]'; '[e-mail]'
AppleMoFo; '[e-mail]'; '[e-mail]';
'[e-mail]'
Apple v. Samsung: Proposed Stipulated Motion for Administrative Relief

Attachments:

2011-12-05 Mtn for Admin Relief re Telephonic M&C.pdf

From:
Sent:
To:
Cc:

Counsel:
Attached please find Apple's proposed Stipulated Motion for Administrative Relief regarding a telephonic meet-and-confer
this week.
Please let me know by 3pm Pacific time on Tuesday, December 6, 2011, whether Samsung will join this Stipulated
Motion.
If we do not hear from you by then we will assume Samsung opposes the Motion.

2011-12-05 Mtn for
Admin Relie...

Regards,
Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile
[phone] fax

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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]
ALISON M. TUCHER (CA SBN 171363)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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 (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

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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 business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New York
corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC, a
Delaware limited liability company,

Case No.

11-cv-01846-LHK

APPLE’S STIPULATED MOTION
FOR ADMINISTRATIVE RELIEF
REGARDING TELEPHONIC
MEET AND CONFER;
PROPOSED ORDER

Defendants.

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In accordance with Civil Local Rules 7-11 and 7-12, Apple Inc. (“Apple”) and Samsung

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Electronics Co., Ltd. (“SEC”), Samsung Electronics America, Inc. (“SEA”), and Samsung

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Telecommunications America, LLC (“STA”) (collectively, “Samsung”), through their respective

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counsel, stipulate and request administrative relief as follows:

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STIPULATED MOTION FOR ADMINISTRATIVE RELIEF REGARDING TELEPHONIC MEET AND CONFER
sf-3079469

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WHEREAS, pursuant to the Court’s August 25, 2011 Minute Order and Case

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Management Order, lead trial counsel for all parties must meet and confer in person before filing

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any discovery motions;

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WHEREAS, Apple has determined, after substantial meet-and-confer discussions amongst

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non-lead trial counsel, that a discovery motion is necessary to resolve certain disputes before the

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winter holidays;

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WHEREAS, Judge Grewal is unavailable the week of December 19, 2011, and counsel

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for Samsung represents that it is unavailable the week of December 26, 2011. As a result, any

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motion not heard by December 16, 2011 may not be heard until January 2012; and

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WHEREAS, Samsung’s lead trial counsel is currently in trial on the East Coast and states
that he is unavailable to meet in person until December 19, 2011;

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NOW, THEREFORE, given the limitations described above, the parties stipulate, subject

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to approval by the Court, that the required lead trial counsel meet-and-confer discussion relating

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to the upcoming discovery motion may take place via telephone or (if available) videoconference.

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IT IS SO STIPULATED:
Dated: December 5, 2011

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MORRISON & FOERSTER LLP
By:

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Attorney for Plaintiff APPLE INC.

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/s/ Michael Jacobs
Michael Jacobs

Dated: December 5, 2011

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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By:

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Attorney for Defendants, SAMSUNG
ELECTRONICS AMERICA, INC. AND
SAMSUNG TELECOMMUNICATIONS
AMERICA, LLC

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STIPULATED MOTION FOR ADMINISTRATIVE RELIEF REGARDING TELEPHONIC MEET AND CONFER
sf-3079469

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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DATED: __________, 2011

________________________________________
The Honorable Lucy H. Koh
United States District Court Judge

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STIPULATED MOTION FOR ADMINISTRATIVE RELIEF REGARDING TELEPHONIC MEET AND CONFER
sf-3079469

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