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

Filing 996

Administrative Motion to File Under Seal Documents Under Seal Re Apples Opposition To Samsungs Motion To Strike Expert Testimony filed by Apple Inc.. (Attachments: #1 Declaration Of Cyndi Wheeler In Support Of Apples Administrative Motion To File Under Seal Documents Re Apples Opposition To Samsungs Motion To Strike Expert Testimony, #2 Declaration Of Mia Mazza In Support Of Apples Administrative Motion To File Documents Under Seal Re Apples Opposition To Samsungs Motion To Strike Expert Testimony, #3 [Proposed] Order Granting Apples Administrative Motion To File Documents Under Seal Re Apples Opposition To Samsungs Motion To Strike, #4 Apples Opposition To Samsungs Motion To Strike Expert Testimony Based On Undisclosed Facts And Theories, #5 Declaration Of Marc J. Pernick In Support Of Apples Opposition To Samsungs Motion To Strike Expert Testimony Based On Undisclosed Facts And Theories, #6 Exhibit Pernick Decl. Ex. 8, #7 Exhibit Pernick Decl. Ex. 10, #8 Exhibit Pernick Decl. Ex. 11, #9 Exhibit Pernick Decl. Ex. 12, #10 Exhibit Pernick Decl. Ex. 16, #11 Exhibit Pernick Decl. Ex. 17, #12 Exhibit Pernick Decl. Ex. 19, #13 Declaration Of Michel Maharbiz, Ph.D. In Support Of Apples Opposition To Samsungs Motion To Strike Expert Testimony, #14 Exhibit Maharbiz Decl. Ex. A, #15 Exhibit Maharbiz Decl. Ex. B, #16 [Proposed] Order Denying Samsungs Motion To Strike Expert Testimony (Dkt. No. 936))(Jacobs, Michael) (Filed on 5/31/2012) Modified on 6/3/2012 pursuant to General Order No. 62, attachment #1 and #2 Sealed (dhm, COURT STAFF).

Exhibit 19

425 MARKET STREET
SAN FRANCISCO
CALIFORNIA 94105-2482
U.S.A.

MO RRI SO N & F O E RST E R L LP

TELEPHONE: [phone]
FACSIMILE: 415.268.7522

T O K YO , L O N D O N , BR U SSE L S,
BE I JI N G , SH AN G H AI , H O N G K O N G

N E W YO RK , SAN F RAN C I SCO ,
L O S A N G E L E S, P A L O A L T O ,
SAC RAME N T O , SAN D I E G O ,
D E N VE R, N O RT H E RN VI RG I N I A,
WASH I N G T O N , D .C.

WWW.MOFO.COM

March 13, 2012

Writer’s Direct Contact
415.268.6024
[e-mail]

By Email ([e-mail])
Sara Jenkins
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 Sara:
The documents previously produced under the Bates ranges APLNDC-Y0000051350-56,
APLNDC0001772330-40, and APLNDC-Y0000232396-430 contain information protected
by the attorney/client privilege, attorney work product doctrine and third party’s rights of
confidentiality. They were included inadvertently in Apple’s production.
In accordance with Paragraph 16 of the parties’ Agreed Upon Protective Order Regarding
Disclosure and Use of Discovery Materials and Federal Rule of Civil Procedure 26(B)(5)(b),
this letter shall serve as notice of this inadvertent production. Please return or destroy all
electronic and paper copies of the previously produced documents, including Exhibit 18 used
at the Buckley deposition.
Sincerely,
/s/ Mia Mazza
Mia Mazza
cc:

S. Calvin Walden
Peter Kolovos

sf-3119693