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

Filing 596

STIPULATION and [Proposed] Order Shortening Time On Schedule For Briefing and Hearing Discovery Motions by Apple Inc.. (Attachments: # 1 Declaration Declaration of Mia Mazza In Support of Stipulation Shortening Time On Schedule For Briefing and Hearing Discovery Motions)(Bartlett, Jason) (Filed on 1/9/2012)

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1 2 3 4 5 6 7 8 9 HAROLD J. MCELHINNY (CA SBN 66781) hmcelhinny@mofo.com MICHAEL A. JACOBS (CA SBN 111664) mjacobs@mofo.com JENNIFER LEE TAYLOR (CA SBN 161368) jtaylor@mofo.com ALISON M. TUCHER (CA SBN 171363) atucher@mofo.com RICHARD S.J. HUNG (CA SBN 197425) rhung@mofo.com JASON R. BARTLETT (CA SBN 214530) jasonbartlett@mofo.com MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: (415) 268-7000 Facsimile: (415) 268-7522 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 (SBN 244180) mark.selwyn@wilmerhale.com WILMER CUTLER PICKERING HALE AND DORR LLP 950 Page Mill Road Palo Alto, California 94304 Telephone: (650) 858-6000 Facsimile: (650) 858-6100 10 11 Attorneys for Plaintiff and Counterclaim-Defendant APPLE INC. 12 13 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 SAN JOSE DIVISION 17 APPLE INC., 18 19 20 21 22 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., 11-cv-01846-LHK (PSG) STIPULATION AND [PROPOSED] ORDER SHORTENING TIME ON SCHEDULE FOR BRIEFING AND HEARING DISCOVERY MOTIONS 23 Defendants. 24 25 26 27 28 STIPULATION AND [PROPOSED] ORD. SHORTENING TIME FOR BRIEFING AND HEARING DISCOVERY MOTS. 11-CV-01846-LHK (PSG) sf-3091970 1 Pursuant to Civil L.R. 6-2, Apple and Samsung file this Stipulation requesting that 2 discovery motions they each plan to file this week are heard on shortened time. This request is 3 supported by the attached Declaration of Mia Mazza in Support of Stipulation to Shorten Time on 4 Schedule for Briefing and Hearing Discovery Motions. 5 WHEREAS, on January 5, 2012, the parties held a lead trial meet-and-confer session in an 6 attempt to resolve several discovery disputes that have arisen between the parties, but after 7 lengthy discussion, some disputes between the parties remain unresolved; 8 9 10 WHEREAS, both parties wish to file discovery motions that will be heard as quickly as possible, to ensure that any resulting Order may allow for timely relief in light of upcoming depositions and the March 8, 2012, fact discovery cutoff; 11 12 WHEREAS, under the proposed expedited schedule, the parties are prepared to waive their respective rights to submit reply memoranda in support of their motions; and 13 WHEREAS, the proposed expedited schedule would not postpone any of the other 14 deadlines set in this case; rather, it would merely provide an avenue for the parties to obtain 15 expedited relief; 16 17 NOW THEREFORE, IT IS HEREBY STIPULATED and agreed to by and between the parties that: 18 1. Each party’s opening briefs shall be filed by Tuesday, January 10, 2012; 19 2. Each party’s opposition briefs shall be filed by 8 a.m. on Tuesday, January 17, 2012; 20 21 22 23 and 3. The hearing on both parties’ motions shall take place on January 18, 2012 at 2:00 P.M., or such other time thereafter as the Court may calendar. IT IS SO STIPULATED. 24 25 26 27 28 STIPULATION AND [PROPOSED] ORD. SHORTENING TIME FOR BRIEFING AND HEARING DISCOVERY MOTS.. 11-CV-01846-LHK (PSG) sf-3091970 1 1 Dated: January 9, 2012 JASON R. BARTLETT MORRISON & FOERSTER LLP 2 3 By: 4 5 6 Dated: January 9, 2012 7 /s/ Jason R. Bartlett JASON R. BARTLETT Attorneys for Apple RACHEL HERRICK KASSABIAN QUINN EMANUEL URQUHART & SULLIVAN, LLP 8 9 By: 10 11 /s/ Rachel Herrick Kassabian RACHEL HERRICK KASSABIAN Attorneys for Samsung 12 *** *** *** 13 14 ORDER 15 Pursuant to Stipulation, and GOOD CAUSE HAVING BEEN SHOWN, IT IS SO 16 ORDERED. 17 18 19 Dated: By: Honorable Paul S. Grewal, U.S.M.J. 20 21 22 23 24 25 26 27 28 STIPULATION AND [PROPOSED] ORD. SHORTENING TIME FOR BRIEFING AND HEARING DISCOVERY MOTS.. 11-CV-01846-LHK (PSG) sf-3091970 2

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