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

Filing 766

MOTION for Leave to File Administrative Request for Leave to File Supplemental Mazza Declaration in Support of Apple's Motion to Compel Timely Production of Foreign-Language and Other Documents in Advance of Related Depositions filed by Apple Inc.. (Attachments: #1 Supplement Supplemental Declaration of Mia Mazza in Support of Apple's Motion to Compel Timely Production of Foreign-Language and Other Documents in Advance of Related Depositions, #2 Exhibit A-1 to the Supplemental Mazza Declaration, #3 Proposed Order Proposed Order)(Hung, Richard) (Filed on 3/4/2012)

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
JENNIFER LEE TAYLOR (CA SBN 161368)
[e-mail]
ALISON M. TUCHER (CA SBN 171363)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,

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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,

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Defendants.
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Case No. 11-cv-01846-LHK
ADMINISTRATIVE REQUEST FOR
LEAVE TO FILE SUPPLEMENTAL
MAZZA DECLARATION IN SUPPORT
OF APPLE’S MOTION TO COMPEL
TIMELY PRODUCTION OF FOREIGNLANGUAGE AND OTHER
DOCUMENTS IN ADVANCE OF
RELATED DEPOSITIONS
Date:
Time:
Place:
Judge:

March 6, 2012
10:00 a.m.
Courtroom 5, 4th Floor
Hon. Paul S. Grewal

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Pursuant to Civil Local Rules 7-3(d) and 7-11, Apple Inc. (“Apple”) hereby requests leave

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of Court to file the Supplemental Declaration of Mia Mazza (“Supplemental Mazza

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Declaration”). Copies of the Supplemental Mazza Declaration and Exhibit A-1 that Apple seeks

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to file are appended to this administrative request.
ADMINISTRATIVE REQUEST FOR LEAVE TO FILE SUPPLEMENTAL MAZZA DECLARATION
CASE NO. 11-cv-01846-LHK (PSG)
sf-3114499

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On February 24, 2012, Apple filed its Reply in Support of its Motion to Compel Timely

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Production of Foreign-Language and Other Documents in Advance of Related Depositions. (Dkt.

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No. 756.) The February 24 Reply included the Declaration of Mia Mazza in Support of Apple’s

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Reply in Support of its Motion to Compel (“Mazza Reply Declaration”). (Dkt. No. 756-1.)

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Exhibit A to the Mazza Reply Declaration was a chart reflecting the following information for

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various Samsung deponents: (1) the deposition date; (2) the deposition time; (3) the production

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date of documents relating to Samsung’s deponent; (4) the production time of those documents;

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(5) the hours differential between the production time and the deposition time; (6) the number of

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documents produced; and (7) number of pages produced. (Dkt. No. 756-2.)

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Since the filing of the Mazza Reply Declaration, the depositions of several more Samsung

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witnesses have taken place or are scheduled for the next several days. Samsung’s pattern of tardy

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production of foreign-language and other documents in advance of related depositions has

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continued, including the production of significant volumes less than three days in advance. An

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updated version of the chart described above may aid the Court’s consideration of the issues

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involved in Apple’s Motion to Compel Timely Production of Foreign-Language and Other

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Documents in Advance of Related Depositions.

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Accordingly, Apple respectfully requests permission to file the accompanying
Supplemental Mazza Declaration.

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Dated: March 4, 2012

MORRISON & FOERSTER LLP

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By:

/s/ Richard S.J. Hung
RICHARD S.J. HUNG
Attorneys for Plaintiff
APPLE INC.

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ADMINISTRATIVE REQUEST FOR LEAVE TO FILE SUPPLEMENTAL MAZZA DECLARATION
CASE NO. 11-cv-01846-LHK (PSG)
sf-3114499

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