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 3
From:
Mazza, Mia
Sent:
Monday, February 13, 2012 8:17 PM
To:
'alexbinder@quinnemanuel.com'; 'rachelkassabian@quinnemanuel.com'
Cc:
AppleMoFo; 'samsungv.apple@quinnemanuel.com'; 'WH Apple Samsung NDCal Service'
Subject: RE: Apple v. Samsung: URGENT - Deposition Scheduling
Alex and Rachel ‐‐
We still have not received dates from you regarding the depositions of the remaining
Samsung witnesses. Nevertheless, we are continuing our good‐faith effort to streamline the
deposition schedule going forward. Accordingly:
Apple has determined that it will not at this time pursue the depositions of ByongChol
Hwang, Hoosoo Seo, Younghee Lee, and Youngseok Bang, but Apple reserves its rights
to seek their depositions at a later time. Note that Younghee Lee is one of the
witnesses to whom Samsung has objected as "apex." This is the fifth "apex" witness
Apple has taken off its deposition schedule since receiving Samsung's February 3, 2012,
letter.
Further, Apple will not pursue the deposition of Yun‐Jung Lee at this time in the N.D.
Cal. action, but this witness's deposition will continue as scheduled in the ITC
investigation.
The below lists 2 and 5 have been adjusted accordingly. There are still 35 depositions left to
be scheduled.
3/8/2012
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