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

Filing 807

DECLARATION of Mia Mazza in Support of #805 Opposition to Administrative Motion for Temporary Relief from the Lead Counsel Meet and Confer Requirement or Alternatively for an Extension of the Deadline to File Motions to Compel, filed by Apple Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N)(Related document(s) #805 ) (Jacobs, Michael) (Filed on 3/13/2012) Modified text on 3/14/2012 (dhm, COURT STAFF).

Exhibit G

755 PAGE MILL ROAD
PALO ALTO
CALIFORNIA 94304-1018
TELEPHONE: [phone]
FACSIMILE: 650.494.0792
WWW.MOFO.COM

March 10, 2012

MORRISON & FOERSTER LLP
NEW YORK, SAN FRANCISCO,
LOS ANGELES, PALO ALTO,
SACRAMENTO, SAN DIEGO,
DENVER, NORTHERN VIRGINIA,
WASHINGTON, D.C.
TOKYO, LONDON, BRUSSELS,
BEIJING, SHANGHAI, HONG KONG

Writer’s Direct Contact
650.813.5718
[e-mail]

Via E-Mail ([e-mail])
Diane Hutnyan
Quinn Emanuel
865 South Figueroa St., 10th Floor
Los Angeles, CA 90017-2543
Re:

Apple v. Samsung, Case No. 11-cv-1846-LHK (N.D. Cal.)

Dear Diane:
This responds to your letter from yesterday regarding the next lead counsel meet-and-confer
session.
Apple too takes the Court’s order requiring an in-person lead counsel meet-and-confer
session very seriously. That is why we proposed four separate days between March 5th and
March 11th when Mr. McElhinny was available to meet with Samsung’s counsel in person.
We even offered to meet on a weekend. Although we understand that all of us have busy
calendars, it is unfortunate that Samsung was not available on any of the dates we suggested,
and that Mr. Verhoeven only had three days during this period when he could meet.
In any event, given both parties’ scheduling constraints, we are open to your suggestions
about how to proceed. If Samsung wants to approach the Court to request relief from Judge
Koh’s August 25, 2011 order, we would join in a motion for administrative relief allowing
non-lead trial counsel to meet and confer. Michael Jacobs is available on Wednesday,
March 14th, and we could meet any time that day in your San Francisco office as requested.
If March 14th works for Samsung, we would propose exchanging agendas by Noon on
March 13th.
Finally, for the record, my March 6th letter did not propose holding the lead counsel meeting
on March 26th. As a courtesy, I was merely informing you that––after Samsung had rejected
our offers to meet on March 5th, March 6th, March 7th, and March 11th––Mr. McElhinny
himself would not be able to attend another lead counsel session in person until March 26th.

pa-1516947

Rachel Herrick Kassabian
March 10, 2012
Page Two
Sincerely,
/s/ Marc J. Pernick
Marc J. Pernick
cc:

Peter Kolovos
S. Calvin Walden

pa-1516947