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

Filing 145

EXHIBITS re #144 Declaration in Support, Exhibits 15-25 to Declaration of Heather H. Martin filed byGoogle Inc.. (Attachments: #1 Exhibit 16, #2 Exhibit 17, #3 Exhibit 18, #4 Exhibit 19, #5 Exhibit 20, #6 Exhibit 21, #7 Exhibit 22, #8 Exhibit 23, #9 Exhibit 24, #10 Exhibit 25)(Related document(s) #144 ) (Candido, Amy) (Filed on 4/28/2012)

EXHIBIT 23

Colin Ward

Lo, Jason C. [[e-mail]]
Tuesday, April24, 2012 4:28PM
Heather Martin
Furman, Joshua; Quinn-Google-N.D.Cal.-00630; Fedman, Emily L.
Re: Apple v. Samsung, No. 12-630 (N.D. Cal.)

From:
Sent:
To:
Cc:
Subject:

Hi Heather:
I would be happy to discuss the issues with you further at 4:40 PT and will give you a call
then. In advance of the call, I would like to point out two things.
First, the portion of Judge Koh's Order that you did not quote in your email makes clear that
the provision you cite applies only to disputes between the parties in the case. Moreover,
your email below was the first indication I had that Google's lead trial counsel wished to
participate in a meet and confer discussion with Apple's lead trial counsel. If that is true
please let me know when Google's lead trial counsel is available this evening, and I will try
to arrange at least a telephonic conference with Apple's lead trial counsel.
Second, we wholeheartedly agree that Judge Koh encouraged "the parties to make all efforts to
keep discovery requests reasonable in scope and narrowly tailored to address the preliminary
injunction motion." But we do not believe that this directive requires Apple to unreasonably
narrow the scope of its discovery. As I have stated to both you and to Mr. Warren, Apple
believes that the discovery it served on Google is appropriately narrow. Accordingly, while
I am happy to discuss the issues further with you, we do not believe that the meet and confer
rules require that we further narrow our already-tailored requests.
Jason

c.

Lo

GIBSON DUNN
Gibson, Dunn & Crutcher LLP
333 South Grand Avenue, Los Angeles, CA 90071-3197 Tel [phone] • Fax [phone]
[e-mail]<mailto:[e-mail]> •
www.gibsondunn.com<http://www.gibsondunn.com/>
From: Heather Martin <[e-mail]<mailto:[e-mail]>>
Date: Tuesday, April 24, 2012 3:32 PM
To: Jason Lo <[e-mail]<mailto:[e-mail]>>
Cc: "Furman, Joshua" <[e-mail]<mailto:[e-mail]», "Quinn-GoogleN.D.Cal.-00630" <[e-mail]<mailto:[e-mail]>>
Subject: Apple v. Samsung, No. 12-630 (N.D. Cal.)
Jason:

I write in response to your email of earlier today, in which you offer to meet and confer
further regarding Google's production of documents in response to the outstanding subpoena in
this matter. We are of course happy to do so, although I am not available until after 4:15
p.m. PDT. Please let me know when following that you would like to talk. I would note,
however, that you and I speaking by telephone is inadequate under Judge Koh's Order Setting
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