Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
636
DECLARATION in Opposition to #602 Administrative Motion to File Under Seal re Samsung's January 10, 2012 Filings Bartlett and Mazza Declarations in Support of Apple's Opposition to Samsung's Motion to Compel filed byApple Inc.. (Attachments: #1 Exhibit 1 to Bartlett Declaration, #2 Exhibit 2 to Bartlett Declaration, #3 Exhibit 3 to Bartlett Declaration, #4 Exhibit 4 to Bartlett Declaration, #5 Exhibit 5 to Bartlett Declaration, #6 Exhibit 6 to Bartlett Declaration, #7 Exhibit 7 to Bartlett Declaration, #8 Exhibit 8 to Bartlett Declaration, #9 Mazza Declaration, #10 Exhibit A to Mazza Declaration, #11 Proposed Order)(Related document(s) #602 ) (Hung, Richard) (Filed on 1/17/2012)
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
UNITED STATES DISTRICT COURT
14
NORTHERN DISTRICT OF CALIFORNIA
15
SAN JOSE DIVISION
16
17
APPLE INC., a California corporation,
Plaintiff,
18
19
20
21
22
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.,
Case No.
11-cv-01846-LHK (PSG)
DECLARATION OF MIA MAZZA
IN SUPPORT OF APPLE’S
OPPOSITION TO SAMSUNG’S
MOTION TO COMPEL
Date:
Time:
Place:
Judge:
23
Defendants.
24
25
26
27
28
MAZZA DECL. ISO APPLE’S OPP. TO SAMSUNG’S MOT. TO COMPEL
CASE NO. 11-CV-01846-LHK (PSG)
sf-3094618
January 19, 2012
10:00 a.m.
Courtroom 5, 4th Floor
Hon. Paul S. Grewal
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 or understand them to be true from
5
members of my litigation team. I make this Declaration in support of Apple’s Opposition to
6
Samsung’s Motion to Compel Apple to Produce Documents and Things.
7
2.
The parties held their first in-person lead trial counsel meeting on January 5, 2012,
8
to discuss the parties’ respective positions on numerous outstanding discovery issues and
9
determine whether those issues could be resolved without court intervention. That same day,
10
before the meeting, Apple sent Samsung a letter setting forth its position on the discovery issues
11
raised by Samsung. That letter is attached as Exhibit B to the Declaration of Jason R. Bartlett in
12
support of Apple’s Opposition to Samsung’s Motion to Enforce Various Court Orders.
13
14
15
3.
At the January 5, 2012 lead trial counsel meeting, Samsung did not raise the issue
of documents relating to “business plans and strategies.”
4.
At the January 5, 2012 lead trial counsel meeting and in follow-up
16
correspondence, the parties mutually agreed to provide deposition dates for all noticed witnesses
17
by January 13, 2012. In accord with that agreement, Apple provided deposition dates for all of
18
the noticed Apple witnesses by January 13, 2012. Attached hereto as Exhibit A is a January 13,
19
2012 email from Samsung’s counsel to Apple’s counsel regarding deposition dates for Samsung
20
witnesses, with the witnesses’ names redacted.
21
22
23
24
25
I declare under penalty of perjury that the foregoing is true and correct. Executed this
17th day of January, 2012, at San Francisco, California.
/s/ Mia Mazza
Mia Mazza
26
27
28
MAZZA DECL. ISO APPLE’S OPP. TO SAMSUNG’S MOT. TO COMPEL
CASE NO. 11-CV-01846-LHK (PSG)
sf-3094618
1
1
2
ATTESTATION OF E-FILED SIGNATURE
I, Richard S.J. Hung, 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 17, 2012
/s/ Richard S.J. Hung
Richard S.J. Hung
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 OPP. TO SAMSUNG’S MOT. TO COMPEL
CASE NO. 11-CV-01846-LHK (PSG)
sf-3094618
1
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?