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

Filing 819

Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Declaration of Kang ISO Motion to Seal DECLARATION UNDER SEAL, #2 Exhibit 1 to Kang: Redacted Samsung's Reply ISO Motion for Protective Order, #3 Exhibit 2 to Kang: Declaration of Kang ISO Samsung's Reply ISO Motion for Protective Order, #4 Declaration of Kassabian ISO Samsung's Reply ISO Motion for Protective Order, #5 Exhibit A to Kassabian, #6 Exhibit B to Kassabian, #7 Exhibit C to Kassabian, #8 Exhibit D to Kassabian, #9 Exhibit E to Kassabian, #10 Exhibit F to Kassabian, #11 Exhibit G to Kassabian, #12 Exhibit H to Kassabian, #13 Exhibit I to Kassabian, #14 Exhibit J to Kassabian, #15 Exhibit K to Kassabian, #16 Exhibit L to Kassabian, #17 Exhibit M to Kassabian, #18 Exhibit N to Kassabian, #19 Exhibit O to Kassabian, #20 Exhibit P to Kassabian, #21 Exhibit Q to Kassabian, #22 Exhibit R to Kassabian, #23 Exhibit S to Kassabian, #24 Exhibit T to Kassabian, #25 Exhibit U to Kassabian, #26 Proposed Order Granting Motio to Seal, #27 Proposed Order Granting's Samsung's Motion for Protective Order Precluding the Depositions of Six High Ranking Executives)(Maroulis, Victoria) (Filed on 3/20/2012) Modified on 3/21/2012 Sealing Declaration of Kang (dhm, COURT STAFF).

EXHIBIT I

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March 16, 2012

By Email ([e-mail])
Rachel Herrick Kassabian
Quinn Emanuel
555 Twin Dolphin Drive, Fifth Floor
Redwood Shores, CA 94065
Re:

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

Dear Rachel:
We write to identify nine Samsung witnesses whose depositions Apple would like to reopen
pursuant to the Court’s May 8, 2012, Order. Apple reserves the right to designate a tenth
witness at a later point in time. As directed by the Court, at least 72 hours in advance of each
scheduled follow-up deposition, Apple will provide a list of the topics it intends to cover.
Junho Park
Tim Benner
Corey Kerstetter
Tim Sheppard
Hyun Goo Woo
Hye Jung Lee
Seung Yun Lee
Oh Chae Kwon
Jae Hwang Sim
For each of these witnesses, a substantial portion of his or her documents were produced with
insufficient time to process (and, where applicable, translate) in advance of the deposition.
In the case of Mr. Sheppard, Apple wishes to reopen his deposition to discuss two key
spreadsheets produced the day before his February 29, 2012, deposition, as well as a new
spreadsheet and additional financial reports from STA to SEC produced shortly after Mr.

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Rachel Herrick Kassabian
March 16, 2012
Page Two
Sheppard’s deposition, on which Samsung has now relied. Apple did not have sufficient
time to analyze these spreadsheets and reports before Mr. Sheppard’s deposition.
Please provide us with dates as soon as possible for the above witnesses’ follow-up
depositions for the week of March 26, 2012. We look forward to hearing from you.
Sincerely,
/s/ Mia Mazza
Mia Mazza
cc:

S. Calvin Walden
Peter Kolovos

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