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

Filing 691

MOTION to Permit Samsung's Expert Samuel Lucente to Review Materials Designated Under the Protective Order filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. Motion Hearing set for 2/7/2012 10:00 AM in Courtroom 5, 4th Floor, San Jose before Magistrate Judge Paul Singh Grewal. Responses due by 2/3/2012. Replies due by 2/6/2012. (Attachments: #1 Declaration of Albert P. Bedecarre, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I, #11 Exhibit J, #12 Exhibit K, #13 Exhibit L, #14 Exhibit M, #15 Proposed Order)(Maroulis, Victoria) (Filed on 1/30/2012)

EXHIBIT I

quinn emanuel trial lawyers | silicon valley
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WRITER'S INTERNET ADDRESS
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January 24, 2012
VIA ELECTRONIC MAIL
Mia Mazza
Morrison & Foerster LLP
425 Market Street
San Francisco, CA 94105-2482
Re:

Apple, Inc. v. Samsung Elecs. Co., et al., No. 11-cv-1846-LHK (N.D. Cal.)

Dear Mia:
I write regarding Apple’s objections to Samsung’s disclosed experts Samuel Lucente and Robert
Anders, as well as Samsung’s objection to Peter Bressler.
Samsung disclosed Mr. Lucente on December 13, 2011 and has responded to two rounds of
inquiry by Apple, neither of which related to issues that would prevent Mr. Lucente from
receiving access to “attorneys eyes only” documents under the protective order in effect in this
matter. We last provided you with information regarding Mr. Lucente on January 20, 2012, and
we have received no response to our letter. Thus, we will now assume that Apple has no further
objection to Mr. Lucente. Unless we hear otherwise by the close of business today, Samsung
will begin providing Mr. Lucente with confidential “attorneys eyes only” documents under the
protective order starting tomorrow morning.
Samsung disclosed Dr. Anders on January 11, 2012 and requested a response from Apple a week
later on January 18, 2012. Apple has made no response whatsoever to this disclosure as of
today’s date, so we can only assume that Apple has no objection to Dr. Anders. Unless we hear
otherwise by the close of business today, Samsung will begin providing Dr. Anders with
confidential “attorneys eyes only” documents under the protective order starting tomorrow
quinn emanuel urquhart & sullivan, llp
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HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Mia Mazza
January 24, 2012
morning.
Finally, after reviewing the issues relating to Peter Bressler and the information provided by
Apple in response to our initial objection, please be advised that Samsung hereby withdraws its
objection to Mr. Bressler receiving confidential “attorneys eyes only” documents under the
protective order.
Very truly yours,
/s/ Rachel Herrick Kassabian
Rachel Herrick Kassabian
RHK
02198.51855/4566041.1

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