NOKIA CORPORATION v. APPLE INC.
Filing
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Memorandum in opposition to re 1 MOTION to Compel Deposition Testimony filed by SALVADOR M. BEZOS, RICHARD COLLER, GLENN PERRY, ROBERT STERNE. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25 Exhibit, # 26 Certificate of Service)(Pickard, Byron)
Exhibit 4
From:
Sent:
To:
Cc:
Subject:
Kale, Rohan
Thursday, April 14, 2011 10:07 AM
Kale, Rohan; Byron Pickard
David Cornwell; Maria Cabico; Hannah J. Robinson; Hemminger, Steve; Newton, Mike
RE: Apple Subpoenas
Byron,
During our meet and confer yesterday, you offered to provide a 30(b)(6) witness on specific topics if we agreed
to withdraw the subpoenas to Messrs. Robert Sterne, Glenn Perry, Rich Coller, and Sal Bezos. This alternative
is unacceptable to us. We believe these individuals have personal knowledge as to non-privileged issues to this
litigation and we intend to go forward with the depositions as indicated in the subpoenas. Please let me know if
you will be proposing alternative deposition dates for Messrs. Sterne, Perry, Coller, and Bezos.
Best Regards,
Rohan
From: Kale, Rohan
Sent: Tuesday, April 12, 2011 10:42 PM
To: Byron Pickard
Cc: David Cornwell; Maria Cabico; Hannah J. Robinson; Nokia-Apple-09-791
Subject: Re: Apple Subpoenas
Byron,
Yes, tomorrow at 3:00 pm works for me.
Rohan
On Apr 12, 2011, at 18:14, "Byron Pickard" wrote:
Rohan,
Can you talk tomorrow at 3 pm?
Byron
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From: Kale, Rohan [mailto:Rohan.Kale@alston.com]
Sent: Tuesday, April 12, 2011 6:06 PM
To: Kale, Rohan; Byron Pickard
Cc: David Cornwell; Maria Cabico; Hannah J. Robinson; Nokia-Apple-09-791
Subject: RE: Apple Subpoenas
Dear Byron,
I write to follow up regarding the outstanding deposition subpoenas to Robert Sterne, Glenn
Perry, Rich Coller, and Sal Bezos. Please let me know when you will be available this week for
a meet and confer to discuss alternate dates for the depositions. If we do not hear back from
you, we will expect Mr. Sterne, Mr. Perry, Mr. Coller, and Mr. Bezos to appear on the dates and
at the location specified in the subpoenas.
Best Regards,
Rohan Kale
Alston & Bird LLP
1201 West Peachtree Street
Atlanta, GA 30309
404-881-7690 - Direct Dial
404-253-8760 - Fax
rohan.kale@alston.com
From: Kale, Rohan
Sent: Monday, April 11, 2011 2:09 PM
To: Byron Pickard
Cc: David Cornwell; Maria Cabico; Hannah J. Robinson; Hemminger, Steve; Newton, Mike
Subject: RE: Apple Subpoenas
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Dear Byron,
I write in response to your letter dated April 8, 2011 regarding the deposition subpoenas to
Robert Sterne, Glenn Perry, Rich Coller, and Sal Bezos. In your letter, you state that questions
concerning reexamination of patents asserted in the litigation will be protected by attorney client
privilege and the attorney work product doctrine. We disagree. Discussions with the Patent
Examiner during the reexamination proceedings are not protected by the work product doctrine
or by attorney client privilege. We also disagree with your characterization of the requests
being for the purpose of harassing Apple's attorneys. We are entitled to deposition testimony on
all matters presented to the Patent Examiner.
Please let me know when you are available for a meet and confer to discuss your concerns and
alternate dates for the depositions.
Best Regards,
Rohan Kale
Alston & Bird LLP
1201 West Peachtree Street
Atlanta, GA 30309
404-881-7690 - Direct Dial
404-253-8760 - Fax
rohan.kale@alston.com
From: Byron Pickard [mailto:bpickard@skgf.com]
Sent: Friday, April 08, 2011 9:18 PM
To: Kale, Rohan
Cc: David Cornwell; Maria Cabico; Hannah J. Robinson
Subject: Apple Subpoenas
Dear Rohan,
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Please see the attached.
Best,
Byron
Byron Pickard
Sterne, Kessler, Goldstein and Fox P.L.L.C.
1100 New York Ave., N.W.
Washington, D.C. 20005
Direct: 202-772-8521
Main: 202-371-2600
Fax: 202-371-2540
e-mail bpickard@skgf.com
www.skgf.com
Assistant: Maria Cabico (202-772-8816)
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