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) DECLARATION OF MIA MAZZA IN SUPPORT OF STIPULATION SHORTENING TIME ON SCHEDULE FOR BRIEFING AND HEARING DISCOVERY MOTIONS 23 Defendants. 24 25 26 27 28 MAZZA DECLARATION ISO STIPULATION SHORTENING TIME FOR BRIEFING AND HRG DISCOVERY MOTS. 11-CV-01846-LHK (PSG) sf-3091919 1 I, Mia Mazza, declare as follows: 2 1. I am an attorney with the law firm of Morrison & Foerster LLP, counsel for Apple. 3 I am licensed to practice law in the State of California. Unless otherwise indicated, I have 4 personal knowledge of the matters stated herein and, if called as a witness, could and would 5 testify competently thereto. I make this declaration in support of the parties’ Stipulation to 6 Shorten Time on Schedule for Briefing and Hearing Discovery Motions. 7 2. On January 5, 2012, the parties held a lead trial meet and confer session in an 8 attempt to resolve several discovery disputes that have arisen between the parties. The meeting 9 lasted three and a half hours and some progress was made during that meeting. Many of the 10 11 12 13 disputes between the parties, however, have not been resolved. 3. The fact discovery cutoff in this case is March 8, 2012. Both parties have noticed a large number of depositions anticipated to take place in January and February, 2012. 4. In light of the upcoming depositions and fact discovery cutoff, both parties wish to 14 file discovery motions that will be heard as quickly as possible, to ensure that any resulting Order 15 may allow for timely relief. 16 5. The Court has granted several motions filed by both parties to shorten time on 17 discovery motions. Most recently, Apple filed a motion to compel on December 8, 2011, and 18 Samsung filed a motion to compel on December 12, 2011. In both cases, the moving party 19 sought and was granted the requested Order shortening time. 20 6. The requested time modification would not affect the overall schedule for the case. 21 In fact, the parties’ request for shortening of time has arisen in large part because the discovery 22 cutoff is less than two months away. 23 24 25 26 I declare under penalty of perjury that the foregoing is true and correct. Executed this 9th day of January, 2012 at San Francisco, California. /s/ Mia Mazza Mia Mazza 27 28 MAZZA DECLARATION ISO STIPULATION SHORTENING TIME FOR BRIEFING AND HRG DISCOVERY MOTS. 11-CV-01846-LHK (PSG) sf-3091919 1 1 2 ATTESTATION OF E-FILED SIGNATURE I, Jason R. Bartlett, am the ECF User whose ID and password are being used to file this 3 Declaration. In compliance with General Order 45, X.B., I hereby attest that Mia Mazza has 4 concurred in this filing. 5 Dated: January 9, 2012 /s/ Jason R. Bartlett Jason R. Bartlett 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MAZZA DECLARATION ISO STIPULATION SHORTENING TIME FOR BRIEFING AND HRG DISCOVERY MOTS. 11-CV-01846-LHK (PSG) sf-3091919 2

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