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

Filing 799

Administrative Motion to File Under Seal filed by Apple Inc.(a California corporation). (Attachments: #1 Proposed Order, #2 [Redacted Public Version] Apple's Combined Reply, #3 Proposed Order, #4 [Redacted Public Version] Declaration of Mia Mazza in Support of Apple's Combined Reply, #5 Exhibit 1 to [Redacted Public Version] of Declaration of Mia Mazza, #6 Exhibit 2 to [Redacted Public Version] of Declaration of Mia Mazza, #7 Exhibit 3 to [Redacted Public Version] of Declaration of Mia Mazza, #8 Exhibit 4 to [Redacted Public Version] of Declaration of Mia Mazza, #9 Exhibit 33 to [Redacted Public Version] of Declaration of Mia Mazza)(Jacobs, Michael) (Filed on 3/12/2012)

Exhibit 1

From:

Mazza, Mia

Sent:

Sunday, February 05, 2012 11:53 AM

To:

'[e-mail]'

Cc:

AppleMoFo; '[e-mail]'; WH Apple Samsung NDCal Service

Subject: Apple v. Samsung: Continued URGENT Need to Finalize Korea Depo Scheduling

Rachel:
As reflected below, I was informed by Victoria on February 1 that you would get back to
me the next morning regarding finalizing the schedule for depositions in Korea. You never
contacted me to discuss that topic. As you know, Apple's team is currently in Korea to take
the noticed depositions of Samsung witnesses. It is important that the schedule be finalized
immediately to avoid wasting the resources Apple has put forth to depose Samsung's
witnesses in the place where they are located.
1. Apple has determined that it will not at this time pursue the depositions of Woncheol
Chae, Chang Hwan Hwang, Eun Go, Paul Golden, David La, and Hankil Yoon, but Apple
reserves its rights to seek their depositions at a later time.
2. In scheduling Korean travel and other arrangements, Apple has relied and is relying on the
following schedule based on the parties' communications, including the discussion thread below:
YoungSoon Lee (February 7)
Sun-Young Yi (February 8)
Hangil Song (February 7/8)  
ByongChol Hwang (February 8)  
Minhkyung Kim (February 10)  
Kiyung Nam (February 10)  
Jong-Kyun Shin (February 13, as noticed)*  
Giyoung Lee (February 16/17)  
Youngseok Bang (February 17)  
Don Joo Lee (February 17)  
Junwon Lee (February 22)   
Yun-Jung Lee (February 23/24)   
Seoggeun Kim (February 29)  
Minhyouk Lee (February 28/29)  
Seung Hun-Yoo (March 2)  

3. Apple would like to depose the following five witnesses during the week of February 13,
on the dates set forth below. Please let us know immediately if a different date that week
works better for any of these witnesses. The dates previously provided for the first four
witnesses are unacceptably late. No date has been provided for the fifth witness. 
Dong Jin Koh (February 14) [Originally noticed for December 5]*
Joon-Il Choi (February 14) [Originally noticed for December 5]
Dong Hoon Chang (February 15) [Originally noticed for January 9]*
Won Pyo Hong (February 15) [Originally noticed for January 12]*

3/8/2012

Suk Geun Kim (February 16) [Originally noticed for January 12]
4. Please let us know which of the following are alternate spellings of the same person's name and
which are different Samsung employees (current or former): 김석근, Soggeun Kim, Seog Guen Kim,
Seok Gun Kim, Suk Keun Kim, and Suk Geun Kim.
5. Please offer dates for the following noticed witnesses. Apple has provided Samsung with dates for
all of the witnesses Samsung has noticed, regardless of objection. Please extend us the same courtesy.
SangEun Lee (noticed for February 1, deposition to take place on or before March 2)  
SeongWon Yoon (noticed for February 1, deposition to take place on or before March 2)  
Seung-Yun Lee (noticed for February 1, deposition to take place on or before March 2)  
In-Ho Kim (noticed for February 2, deposition to take place on or before March 2)  
Jon-Sik Seong (noticed for February 3, deposition to take place on or before March 2)  
Byeong-Wook Kim (noticed for February 6, deposition to take place on or before March 2)  
Kun Ro (noticed for February 6, deposition to take place on or before March 2)  
Hyoung-Shin Park (noticed for February 6, deposition to take place on or before March 2)  
Heonbae Kim (noticed for February 6, deposition to take place on or before March 2)  
Seunghwan Cho (noticed for February 6, deposition to take place on or before March 2)  
Dae-Woon Myeong (noticed for February 7, deposition to take place on or before March 2)  
YoungHoon Eom (noticed for February 8, deposition to take place on or before March 2)*  
Min-Cheol Shin (noticed for February 8, deposition to take place on or before March 2)*  
Gee Sung Choi (noticed for February 8, deposition to take place on or before March 2)  
Sungsik Lee (noticed for February 9, deposition to take place on or before March 2)  
Younghee Lee (noticed for February 10, deposition to take place on or before March 2)*  
Sang Hung (noticed for February 10, deposition to take place on or before March 2)  
DongSeok Ryu (noticed for February 13, deposition to take place on or before March 2)  
Hoosoo Seo (noticed for February 14, deposition to take place on or before March 2)  

6. Please provide witnesses and dates for the topics set forth in Apple's 8 outstanding 30(b)(6) notices.
To date, Samsung has not yet provided a single witness or date for any of the notices Apple has served
beginning in October 2011. 

7. Apple's acknowledges Samsung's February 3 letter stating its objections to Apple deposing the
eight witnesses designated with an asterisk (*) above. We will address that issue, and Samsung's
proposed limitation to the scope of Mr. Don Joo Lee's February 17 deposition, in separate
correspondence. Apple does not agree to any such limitation of the scope of its deposition of Mr. Lee. 

Deposition scheduling is already on Apple's agenda for this Monday's lead trial counsel meeting. I hope
that Samsung will, before then, provide the requested dates for these 24 witnesses so that we do not need
to take up lead counsel's time on this scheduling matter. 

Regards, 

Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile

3/8/2012