Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 630

STIPULATION WITH PROPOSED ORDER re #610 Stipulation and Order to Enlarge Time for Briefing the Parties' Pending Discovery Motions filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Declaration Declaration of Rachel Herrick Kassabian)(Maroulis, Victoria) (Filed on 1/16/2012)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
2 [e-mail]
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
6 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
7 555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
8 Telephone: [phone]
Facsimile: [phone]
9
Michael T. Zeller (Cal. Bar No. 196417)
10 [e-mail]
865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
14 AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 APPLE INC., a California corporation,
Plaintiff,

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vs.

CASE NO. 11-cv-01846-LHK
DECLARATION OF RACHEL HERRICK
KASSABIAN IN SUPPORT OF THE
STIPULATION TO ENLARGE TIME
FOR BRIEFING

21 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
22 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
23 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
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Defendants.
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Case No. 11-cv-01846-LHK
KASSABIAN DECLARATION IN SUPPORT OF STIPULATION TO ENLARGE TIME

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I, Rachel Herrick Kassabian, declare:

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1. I am a partner in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

3 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc. and Samsung
4 Telecommunications America, LLC (collectively, “Samsung”).

I have personal knowledge of

5 the facts set forth in this declaration and, if called upon as a witness, I could and would testify as
6 follows.
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2. On January 5, 2012, the parties held a lead trial counsel meet and confer session to

8 resolve a number of discovery disputes that had arisen between the parties.

Although some

9 progress was made, both parties stated their intent to file discovery motions on various unresolved
10 issues.

The parties agreed to a shortened briefing schedule on their respective motions and filed

11 a stipulation to that effect, which was granted by the Court.
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(See Dkt No. 610).

3. Pursuant to the stipulated briefing schedule, the parties’ opening briefs were due

13 January 10, 2012 and opposition briefs are due by Tuesday, January 17, 2012 at 8 a.m.
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(Id.)

4. The parties have now determined that they require additional time to complete their

15 opposition briefing relating to these motions, and have agreed that each party should have until 5
16 p.m. on January 17 to do so.
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5. The requested time modification will not affect any other deadline in this case.

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I declare under penalty of perjury that the foregoing is true and correct.

Executed in San

20 Francisco, California on January 16, 2011.
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/s/ Rachel Herrick Kassabian

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Case No. 11-cv-01846-LHK
-2KASSABIAN DECLARATION IN SUPPORT OF STIPULATION TO ENLARGE TIME

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ATTESTATION OF E-FILED SIGNATURE
I, Victoria Maroulis, am the ECF User whose ID and password are being used to file this

3 Stipulation.

In compliance with General Order 45, X.B., I hereby attest that Rachel Herrick

4 Kassabian has concurred in this filing.
5
6 Dated: January 16, 2011

/s/ Victoria Maroulis
Victoria Maroulis

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Case No. 11-cv-01846-LHK
-3KASSABIAN DECLARATION IN SUPPORT OF STIPULATION TO ENLARGE TIME