Apple Inc. v. Samsung Electronics Co. Ltd. et al
Administrative Motion to File Under Seal Samsung's Motion to Enforce April 12, 2012 Order filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Samsung's Motion to Enforce April 12, 2012 Order (Public Redacted Version), #2 Declaration of Diane C. Hutnyan In Support of Samsung's Motion to Enforce April 12, 2012 Order, #3 Exhibit 1, #4 Exhibit 2, #5 Exhibit 3, #6 Exhibit 4, #7 Exhibit 5, #8 Exhibit 6, #9 Exhibit 7, #10 Exhibit 8, #11 Exhibit 9, #12 Exhibit 10, #13 Exhibit 11, #14 Proposed Order Granting Samsung's Motion to Enforce April 12, 2012 Order)(Maroulis, Victoria) (Filed on 5/22/2012)
Bartlett, Jason R.
Diane Hutnyan; Mazza, Mia
AppleMoFo; WH Apple Samsung NDCal Service; Samsung v. Apple
RE: Apple v. Samsung Discovery Correspondence
Wednesday, May 09, 2012 1:56:08 PM
Despite our prior requests asking that you identify your desired deponents promptly, you are sending us this list just one day before Judge Grewal's
May 10th deadline for taking these depositions. This is despite our production of the last of these transcripts on April 21st -- eighteen days ago,
and six days before Judge Grewal's April 27th deadline for compliance.
Moreover, despite our prior requests that you explain with specificity how any requested depositions are reasonably occasioned by our transcript
production, you have not done so. Indeed, the names of at least some of the individuals identified below do not even appear in the transcripts
produced. Samsung also affirmatively declined to take Saku Hieta's deposition previously. For Emilie Kim, Samsung previously deposed her for all
of one hour, despite Ms. Kim's setting aside an entire day for her deposition. Finally, as Samsung is well aware, it has already deposed Richard
Howarth for more than thirteen hours.
Please explain, with specific citations to transcript pages, why Samsung believes that it is entitled to take these depositions. Please provide your
response by no later than 9pm tonight, so that we can determine whether we need to raise Samsung's very late demand for these depositions with
Jason R. Bartlett
Morrison & Foerster
425 Market St.
San Francisco, CA 94105
From: Diane Hutnyan [mailto:firstname.lastname@example.org]
Sent: Wednesday, May 09, 2012 12:21 AM
To: Mazza, Mia
Cc: AppleMoFo; WH Apple Samsung NDCal Service; Samsung v. Apple
Subject: Apple v. Samsung Discovery Correspondence
Please find below the list of deponents that Samsung has selected for further deposition pursuant to the April 12, 2012 Court order.
1. Richard Howarth
2. Emilie Kim
3. Saku Hieta
4. Priya Balasubramaniam
5. Andrew Bright
Apple should immediately provide dates that these witnesses are available for deposition. Due to time constraints, Samsung is willing to
stipulate to extend the time to depose these individuals past May 10, 2012, provided that all depositions take place by May 18, 2012. Samsung
expects that Apple will be willing to so stipulate as it withheld more than 200 deposition transcripts, amounting to more than 20,000 total
pages of testimony. If Apple is unwilling to stipulate, then we expect the identified deponents to appear for deposition on May 10 at our
offices in Redwood Shores.
We look forward to hearing from you.
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