Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
598
MOTION for Protective Order Regarding Samsung's First Rule 30(b)(6) Deposition Notice filed by Apple Inc.. Motion Hearing set for 1/18/2012 02:00 PM in Courtroom 5, 4th Floor, San Jose before Magistrate Judge Paul Singh Grewal. Responses due by 1/13/2012. (Attachments: #1 McElhinny Declaration, #2 Exhibit A, #3 Exhibit B, #4 Mazza Declaration, #5 Exhibit A, #6 Exhibit B, #7 Exhibit C, #8 Exhibit D, #9 Proposed Order)(Jacobs, Michael) (Filed on 1/10/2012)
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 MOTION FOR
PROTECTIVE ORDER
REGARDING SAMSUNG’S FIRST
30(b)(6) DEPOSITION NOTICE
23
Defendants.
24
25
26
27
28
MAZZA DECL. ISO APPLE’S MOTION FOR PROTECTIVE ORDER RE SAMSUNG’S FIRST 30(B)(6) NOTICE
11-CV-01846-LHK (PSG)
sf-3091574
1
I, Mia Mazza, declare as follows:
2
1.
I am a partner in the law firm of Morrison & Foerster LLP, counsel for Apple Inc.
3
(“Apple”). I am licensed to practice law in the State of California. Unless otherwise indicated, I
4
have 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 Apple’s Motion for Protective
6
Order Regarding Samsung’s First Rule 30(b)(6) Deposition Notice.
7
8
9
10
11
12
2.
Attached hereto as Exhibit A is a true and correct copy of Samsung’s First Rule
30(b)(6) Notice to Apple Inc., served on December 14, 2011.
3.
Attached hereto as Exhibit B is a true and correct copy of correspondence dated
December 27, 2011, from counsel for Apple to counsel for Samsung.
4.
Attached hereto as Exhibit C is a true and correct copy of correspondence dated
December 31, 2011, from counsel for Samsung to counsel for Apple.
13
5.
14
January 3, 2012.
15
6.
Attached hereto as Exhibit D is a true and correct copy of correspondence dated
On September 16, 2011, Samsung propounded its Second Set of Interrogatories to
16
Apple Inc., containing Interrogatory Nos. 19–32. Interrogatory No. 19 reads as follows:
17
“Separately for each APPLE ACCUSED PRODUCT, IDENTIFY: (1) Separately for each
18
APPLE ACCUSED PRODUCT, IDENTIFY: (1) the Baseband Processor used; (2) the
19
Executable Software incorporated or installed in the APPLE ACCUSED PRODUCT; (2) the 3
20
GPP Release(s) supported (including which versions and subversions of the 3GPP specification
21
are supported within each Release); (3) the version(s) of HSUPA supported; and (4) the
22
version(s) of HSDPA supported, and IDENTIFY any documents which reflect these categories of
23
information. Interrogatory No. 20 reads as follows: Separately for each APPLE ACCUSED
24
PRODUCT and each Baseband Processor, IDENTIFY the Software or portions of Software
25
(including corresponding file name and line numbers) for performing multiplexing, channel
26
coding, interleaving, demultiplexing of radio frames, generating scrambling codes and/or rate
27
matching, or state which of these functions are not performed by the APPLE ACCUSED
28
MAZZA DECL. ISO APPLE’S MOTION FOR PROTECTIVE ORDER RE SAMSUNG’S FIRST 30(B)(6) NOTICE
11-CV-01846-LHK (PSG)
sf-3091574
1
1
PRODUCT or Baseband Processor. Apple responded to both of these Interrogatories on
2
October 26, 2011.
3
7.
I have asked my litigation team to review the transcripts of depositions taken by
4
Samsung in this case to determine the number of hours of deposition time Samsung has used up
5
in post-Preliminary Injunction, party depositions. My team calculated that Samsung has used up
6
105 hours of its allotted 250 hours, leaving less than 145 hours for their remaining depositions.
7
8
9
10
I declare under penalty of perjury that the foregoing is true and correct. Executed this
10th day of January, 2012 at San Francisco, California.
/s/ Mia Mazza
Mia Mazza
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MAZZA DECL. ISO APPLE’S MOTION FOR PROTECTIVE ORDER RE SAMSUNG’S FIRST 30(B)(6) NOTICE
11-CV-01846-LHK (PSG)
sf-3091574
2
1
2
ATTESTATION OF E-FILED SIGNATURE
I, Michael A. Jacobs, 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 10, 2012
/s/ Michael A. Jacobs
Michael A. Jacobs
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MAZZA DECL. ISO APPLE’S MOTION FOR PROTECTIVE ORDER RE SAMSUNG’S FIRST 30(B)(6) NOTICE
11-CV-01846-LHK (PSG)
sf-3091574
3
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?