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

Filing 789

STIPULATION WITH PROPOSED ORDER STIPULATION AND [PROPOSED ORDER] REGARDING SCHEDULE FOR BRIEFING APEX-RELATED MOTION TO COMPEL AND MOTION FOR PROTECTIVE ORDER filed by Apple Inc.(a California corporation). (Jacobs, Michael) (Filed on 3/8/2012)

1

Counsel Information Appears on the Following Page

2
3
4
5
6
7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10

SAN JOSE DIVISION

11
12

APPLE INC.,

13
14
15
16
17
18
19

Case No.
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,

11-cv-01846-LHK (PSG)

STIPULATION AND [PROPOSED]
ORDER REGARDING SCHEDULE
FOR BRIEFING APEX-RELATED
MOTION TO COMPEL AND
MOTION FOR PROTECTIVE
ORDER

Defendant.

20
21
22
23
24
25
26
27
28
STIPULATION RE BRIEFING SCHEDULE FOR APPLE’S AND SAMSUNG’S APEX-RELATED MOTIONS
11-cv-01846-LKH (PSG)
sf-3117720

1

Pursuant to Civil L.R. 6-2, Apple and Samsung file this Stipulation requesting that the

2

Court revise the briefing schedule for Apple’s Apex Motion and Samsung’s related Protective

3

Order Motion.

4

WHEREAS, on February 16, 2012, Apple filed and served a Motion to Compel

5

Depositions of 14 of Samsung’s Purported “Apex” Witnesses (“Apex Motion”) (Docket

6

No. 736);

7
8

WHEREAS, on February 23, 2012, Samsung filed and served a Motion for Protective
Order (“Protective Order Motion”) relating to the Apex Motion (Docket No. 754-2);

9

WHEREAS, Apple’ opposition to the Protective Order Motion and its reply in support of

10

the Apex Motion are currently due on March 8 and March 15, 2012, respectively, and Samsung’s

11

reply in support of the Protective Order Motion is currently due on March 15, 2012;

12

WHEREAS, the parties agree that Apple’s opposition and reply briefs should be

13

combined into a single brief to reduce the total number of briefs filed with the Court on apex-

14

related issues; and

15
16
17
18
19

WHEREAS, the proposed adjusted schedule would not postpone any of the other
deadlines set in this case;
NOW THEREFORE, IT IS HEREBY STIPULATED and agreed to by and between the
parties that:
1.

Apple’s opposition to Samsung’s Protective Order Motion, and Apple’s reply in

20

support of its Apex Motion, shall be filed as a single brief, not to exceed 25 pages, no later than

21

March 12, 2012.

22

2.

23

March 19, 2012.

Samsung’s reply in support of its Protective Order Motion shall be filed on

24
25
26
27
28
STIPULATION RE BRIEFING SCHEDULE FOR APPLE’S AND SAMSUNG’S APEX-RELATED MOTIONS
11-cv-01846-LKH (PSG)
sf-3117720

1

1
2

IT IS SO STIPULATED.
Dated: March 8, 2012

MORRISON & FOERSTER LLP

3
4

By:

5

MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

6
7
8

Attorneys for Plaintiff
APPLE INC.

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

/s/ Michael A. Jacobs
Michael A. Jacobs

Dated: March 8, 2012

RACHEL HERRICK KASSABIAN
QUINN EMANUEL URQUHART &
SULLIVAN, LLP

By:

/s/ Rachel Herrick Kassabian
Rachel Herrick Kassabian
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
Telephone: [phone]
Facsimile: [phone]
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS
AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS
AMERICA, LLC

28
STIPULATION RE BRIEFING SCHEDULE FOR APPLE’S AND SAMSUNG’S APEX-RELATED MOTIONS
11-cv-01846-LKH (PSG)
sf-3117720

2

1

ORDER

2

Based on the foregoing stipulation,

3

IT IS SO ORDERED.

4
5
6
7

Dated:
HONORABLE PAUL S. GREWAL
United States Magistrate Judge

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION RE BRIEFING SCHEDULE FOR APPLE’S AND SAMSUNG’S APEX-RELATED MOTIONS
11-cv-01846-LKH (PSG)
sf-3117720

3

1
2
3
4

ATTESTATION OF E-FILED SIGNATURE
I, Michael A. Jacobs, am the ECF User whose ID and password are being used to file this
Stipulation. In compliance with General Order 45, X.B., I hereby attest that Rachel Herrick
Kassabian has concurred in this filing.

5
6
7

Dated: March 8, 2012

/s/ Michael A. Jacobs
Michael A. Jacobs

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION RE BRIEFING SCHEDULE FOR APPLE’S AND SAMSUNG’S APEX-RELATED MOTIONS
11-cv-01846-LKH (PSG)
sf-3117720

4