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)

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.
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

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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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5.

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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