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