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

Filing 822

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Proposed Order, #2 [Redacted Public Version] Apple's Reply Brief, #3 [Redacted Public Version] Olson Reply Declaration, #4 Exhibit C to [Redacted Public Version] Olson Reply Declaration, #5 Exhibit E to [Redacted Public Version] Olson Reply Declaration, #6 Exhibit G to [Redacted Public Version] Olson Reply Declaration, *** DOCUMENT LOCKED [822-7] AT FILER'S REQUEST. *** #7 Exhibit I to [Redacted Public Version] Olson Reply Declaration, #8 [Redacted Public Version] Roberts Reply Declaration, #9 [Redacted Public Version] Kim Reply Declaration, #10 Exhibit 1 to [Redacted Public Version] Kim Reply Declaration, #11 Exhibit 2 to [Redacted Public Version] Kim Reply Declaration, #12 Exhibit 3 to [Redacted Public Version] Kim Reply Declaration, #13 Exhibit 4 to [Redacted Public Version] Kim Reply Declaration, #14 Exhibit 5 to [Redacted Public Version] Kim Reply Declaration, #15 Exhibit 6 to [Redacted Public Version] Kim Reply Declaration, #16 Exhibit 7 to [Redacted Public Version] Kim Reply Declaration, #17 Exhibit 8 Part 1 to [Redacted Public Version] Kim Reply Declaration, #18 Exhibit 8 Part 2 to [Redacted Public Version] Kim Reply Declaration, #19 Exhibit 11 to [Redacted Public Version] Kim Reply Declaration, #20 Exhibit 12 to [Redacted Public Version] Kim Reply Declaration, #21 Certificate/Proof of Service)(Jacobs, Michael) (Filed on 3/20/2012) Modified on 3/21/2012 (wv, COURT STAFF). Modified on 3/21/2012 (wv, COURT STAFF).

EXHIBIT E

quinn emanuel

trial lawyers | los angeles

865 South Figueroa Street, 10th Floor, Los Angeles, California 90017-2543 | TEL: [phone] FAX: [phone]

February 24, 2012

VIA ELECTRONIC MAIL
Marc J. Pernick, Esq.
Morrison Foerster
755 Page Mill Road
San Francisco, California 94304-1018
Re:

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

Dear Marc:
I write in response to your letter of February 19, 2012 regarding Samsung’s designation of Tim
Sheppard as a 30(b)(6) witness.
Subject to Samsung's objections, Tim Sheppard will testify on behalf of STA and SEA on the
following topics as set forth in Apple’s Seventh 30(b)(6) Notice: 1, 6 (as to sales plans), 7, 13,
14, 17, 22, 26 (as to sales plans), 27 (as to sales plans), and 30. Mr. Sheppard will not testify on
the following topics, and Samsung hereby withdraws his designation as to them: 2, 3, 4, 5, 15,
16, 20, and 23. Mr. Sheppard is not a 30(b)(6) witness for Samsung Electronics Co., Ltd., nor is
he currently designated as to any topics in Apple Tenth 30(b)(6) Notice.
Mr. Sheppard has already made travel plans and re-arranged his busy schedule to attend the
deposition, so please let us know immediately if Apple does not intend to proceed on
February 29. If we do not receive confirmation by 5:00 p.m. today that Apple will proceed on
February 29, we will assume the deposition is not going forward on that date.
quinn emanuel urquhart & sullivan, llp
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Very truly yours,
/s/ Anthony P. Alden
Anthony P. Alden
02198.51855/4619209.1

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