Motorola Mobility, Inc. v. Apple, Inc.

Filing 197

RESPONSE in Support re 178 MOTION to Strike Motorola's Supplemental Infringement Contentions filed by Apple, Inc.. (Attachments: # 1 Affidavit Haskett Declaration, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4)(Pace, Christopher)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 1:10-CV-23580-UU

MOTOROLA MOBILITY, INC.,
Plaintiff,
v.
APPLE INC.,
Defendant.

APPLE INC.,
Counterclaim-Plaintiff,
v.
MOTOROLA, INC. and
MOTOROLA MOBILITY, INC.,
Counterclaim-Defendants.

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DECLARATION OF CHRISTINE SAUNDERS HASKETT
IN SUPPORT OF DEFENDANT AND COUNTERCLAIM-PLAINTIFF APPLE INC.’S
REPLY IN SUPPORT OF MOTION TO STRIKE MOTOROLA’S SUPPLEMENTAL
INFRINGEMENT CONTENTIONS

I, Christine Saunders Haskett, hereby declare:
1.

I am a partner with the law firm of Covington & Burling LLP, counsel of record for

Apple Inc. (“Apple”) in the above-captioned matter. The matters referenced in this declaration
are based on personal knowledge and belief and if called as a witness I could, and would, testify
competently to these matters.
2.

Attached hereto as Exhibit 1 is a true and correct copy of current Patent Local Rule 3-1 in

the United States District Court for the Northern District of California.
3.

Attached hereto as Exhibit 2 is a true and correct copy of the Preliminary Pretrial

Conference Order entered by Judge Barbara B. Crabb in case number 10-CV-662 between Apple
and Motorola in the United States District Court for the Western District of Wisconsin.
4.

Attached hereto as Exhibit 3 is a true and correct copy of the infringement contentions

Motorola served on March 4, 2011 in case number 10-CV-662 between Apple and Motorola in
the United States District Court for the Western District of Wisconsin.
5.

Attached hereto as Exhibit 4 is a true and correct copy of an e-mail dated March 4, 2011

from Steven Cherensky, counsel for Apple, to Edward DeFranco, counsel for Motorola.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct to the best of my knowledge and belief.
Executed on December 5, 2011 at San Francisco, California.

__/s/ Christine Saunders Haskett________
Christine Saunders Haskett

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CERTIFICATE OF SERVICE
I hereby certify that on December 5, 2011, I filed the foregoing document with the Clerk
of the Court. I also certify that the foregoing document is being served this day on all counsel of
record identified on the attached Service List via email and CM/ECF.

/s/ Christopher R. J. Pace
Christopher R.J. Pace (Fla. Bar No. 0721166)

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SERVICE LIST
Case No. 1:10cv023580-Civ-UU

Edward M. Mullins
Fla. Bar No. 863920
[e-mail]
ASTIGARRAGA DAVIS MULLINS & GROSSMAN, P.A.
701 Brickell Avenue, 16th Floor
Miami, FL 33131
Telephone: [phone]
Facsimile: [phone]
Attorneys for Motorola Mobility, Inc.
Electronically served via CM/ECF and via email
Of Counsel:
Charles K. Verhoeven
David A. Perlson
Anthony Pastor
QUINN EMANUEL URQUHART & SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, CA 93111
[phone]
Raymond N. Nimrod
Edward J. DeFranco
QUINN EMANUEL URQUHART & SULLIVAN, LLP
51 Madison Avenue, 22nd Floor
New York, NY 10010
[phone]
David A. Nelson
QUINN EMANUEL URQUHART & SULLIVAN, LLP
500 West Madison Street, Suite 2450
Chicago, IL 60661
[phone]
[e-mail]
Attorneys for Motorola Mobility, Inc.
Electronically served via email

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