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

Filing 728

*** FILED IN ERROR. REFER TO DOCUMENT #730 . *** Declaration of Marc J. Pernick in Support of #727 Reply to Opposition/Response, filed byApple Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13)(Related document(s) #727 ) (Hung, Richard) (Filed on 2/13/2012) Modified on 2/14/2012 (feriab, COURT STAFF).

EXHIBIT 3

Page 1 of 2

From:

Ahn, Deok Keun Matthew

Sent:

Tuesday, December 20, 2011 4:48 PM

To:

'Alex Binder'; 'Melissa Chan'; '[e-mail]'; Victoria Maroulis; Margret Caruso;
Todd Briggs; Rachel Herrick Kassabian

Cc:

Mazza, Mia

Subject: RE: Apple Inc. v. Samsung Electronics Co., Ltd. et al.: Discovery
Counsel,
The original message below requests a departure from the procedures in the protective order in this
case. If someone on your team is available to discuss this request, please call me.
best regards,
Matt
Deok Keun Matthew Ahn | Morrison & Foerster LLP
425 Market Street, San Francisco, California 94105
[e-mail] | tel: [phone] | fax: [phone]

From: Ahn, Deok Keun Matthew
Sent: Tuesday, December 20, 2011 11:48 AM
To: 'Alex Binder'; 'Melissa Chan'; '[e-mail]'
Cc: Mazza, Mia
Subject: RE: Apple Inc. v. Samsung Electronics Co., Ltd. et al.: Discovery
Melissa or Sara,
I haven't been able to get a hold of Alex about this. Can one of you call me today?
thanks,
Matt
Deok Keun Matthew Ahn | Morrison & Foerster LLP
425 Market Street, San Francisco, California 94105
[e-mail] | tel: [phone] | fax: [phone]

From: Ahn, Deok Keun Matthew
Sent: Monday, December 19, 2011 8:39 PM
To: 'Alex Binder'
Subject: RE: Apple Inc. v. Samsung Electronics Co., Ltd. et al.: Discovery
Alex,
Please call me at 415-268-6629 regarding your email.
thanks,

Page 2 of 2

Matt
Deok Keun Matthew Ahn | Morrison & Foerster LLP
425 Market Street, San Francisco, California 94105
[e-mail] | tel: [phone] | fax: [phone]

From: Alex Binder [mailto:[e-mail]]
Sent: Tuesday, December 13, 2011 5:46 PM
To: AppleMoFo; [e-mail]; Ahn, Deok Keun Matthew; Tucher, Alison M.;
Jacobs, Michael A.; McElhinny, Harold J.; Bartlett, Jason R.; [e-mail];
[e-mail]
Cc: Victoria Maroulis; Margret Caruso; Todd Briggs; Rachel Herrick Kassabian
Subject: Apple Inc. v. Samsung Electronics Co., Ltd. et al.: Discovery

Counsel,
Samsung hereby discloses Samuel Lucente as an expert in this case. Attached are Mr. Lucente curriculum
’s
vitae, which includes his current employer and each entity from which he has received compensation in his area
of expertise over the last 5 years, and Mr. Lucente’s signed undertaking of the Interim Model Protective Order.
Please note that Mr. Lucente does not have any previous litigation history.
Please let us know by December 20, 2011 whether Apple objects, and the grounds for such objection, to
disclosure to Mr. Lucente of Apple information designated in this litigation as “Highly Confidential – Attorney’s
Eyes Only,” and “Highly Confidential – Source Code” under the Interim Model Protective Order.
Alex Binder
Associate,
Quinn Emanuel Urquhart & Sullivan, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
415-875-6408 Direct
415.875.6600 Main Office Number
415.875.6700 FAX
[e-mail]
www.quinnemanuel.com
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