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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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.,

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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.,

11-cv-01846-LHK (PSG)

STIPULATION AND [PROPOSED]
ORDER SHORTENING TIME ON
SCHEDULE FOR BRIEFING AND
HEARING DISCOVERY
MOTIONS

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Defendants.
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STIPULATION AND [PROPOSED] ORD. SHORTENING TIME FOR BRIEFING AND HEARING DISCOVERY MOTS.
11-CV-01846-LHK (PSG)
sf-3091970

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Pursuant to Civil L.R. 6-2, Apple and Samsung file this Stipulation requesting that

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discovery motions they each plan to file this week are heard on shortened time. This request is

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supported by the attached Declaration of Mia Mazza in Support of Stipulation to Shorten Time on

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Schedule for Briefing and Hearing Discovery Motions.

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WHEREAS, on January 5, 2012, the parties held a lead trial meet-and-confer session in an

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attempt to resolve several discovery disputes that have arisen between the parties, but after

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lengthy discussion, some disputes between the parties remain unresolved;

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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;

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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

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WHEREAS, the proposed expedited schedule would not postpone any of the other

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deadlines set in this case; rather, it would merely provide an avenue for the parties to obtain

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expedited relief;

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NOW THEREFORE, IT IS HEREBY STIPULATED and agreed to by and between the
parties that:

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1. Each party’s opening briefs shall be filed by Tuesday, January 10, 2012;

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2. Each party’s opposition briefs shall be filed by 8 a.m. on Tuesday, January 17, 2012;

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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.

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STIPULATION AND [PROPOSED] ORD. SHORTENING TIME FOR BRIEFING AND HEARING DISCOVERY MOTS..
11-CV-01846-LHK (PSG)
sf-3091970

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Dated: January 9, 2012

JASON R. BARTLETT
MORRISON & FOERSTER LLP

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By:
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Dated: January 9, 2012

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/s/ Jason R. Bartlett
JASON R. BARTLETT
Attorneys for Apple

RACHEL HERRICK KASSABIAN
QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By:

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/s/ Rachel Herrick Kassabian
RACHEL HERRICK KASSABIAN
Attorneys for Samsung

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*** *** ***
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ORDER
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Pursuant to Stipulation, and GOOD CAUSE HAVING BEEN SHOWN, IT IS SO
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ORDERED.
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Dated:

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

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STIPULATION AND [PROPOSED] ORD. SHORTENING TIME FOR BRIEFING AND HEARING DISCOVERY MOTS..
11-CV-01846-LHK (PSG)
sf-3091970

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