Motorola Mobility, Inc. v. Apple, Inc.
Filing
224
MOTION to Compel Responses to Interrogatories Regarding Set-Top Box Patents (Nos. 19-22) by Apple, Inc.. Responses due by 2/16/2012 (Attachments: # 1 Affidavit Declaration of Jill Ho, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C-SEALED, # 5 Exhibit D-SEALED, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R, # 20 Exhibit S, # 21 Exhibit T, # 22 Exhibit U-SEALED, # 23 Exhibit V-SEALED, # 24 Exhibit W-SEALED, # 25 Exhibit X-SEALED, # 26 Exhibit Y-SEALED, # 27 Exhibit Z-SEALED, # 28 Exhibit AA-SEALED, # 29 Exhibit BB-SEALED, # 30 Exhibit CC-SEALED, # 31 Exhibit DD-SEALED, # 32 Text of Proposed Order)(Pace, Christopher)
EXHIBIT J
Ho, Jill
From:
Sent:
To:
Subject:
Ho, Jill
Monday, December 12, 2011 6:57 AM
Samuels, Joel
Re: Motorola v. Apple: Suddenlink Communications Subpoena [HDPSTL_Legal.FID860559]
Importance:
High
Hi Joel,
That is correct. Per our prior correspondence, we are not expecting any production from Suddenlink at this time. I will follow
up with you if we don't get what we need from Motorola.
Best regards,
Jill
From: Joel Samuels
Date: Mon, 12 Dec 2011 14:51:18 +0000
To: Jill Schmidt
Subject: RE: Motorola v. Apple: Suddenlink Communications Subpoena [HDP‐STL_Legal.FID860559]
Jill:
Since the compliance date specified in the subpoena is this Friday, I would like to confirm that 1) Apple needs no
information from Suddenlink, and 2) that Suddenlink does not need to respond by the 16th as specified in the subpoena.
Hope all is well,
‐ Joel
Joel R. Samuels | Attorney at Law
O | 314.726.7509 F | 314.726.7501
Patent, Trademark & Copyright Law
From: Ho, Jill [mailto:jill.ho@weil.com]
Sent: Wednesday, November 30, 2011 1:19 PM
To: Samuels, Joel
Subject: RE: Motorola v. Apple: Suddenlink Communications Subpoena [HDP-STL_Legal.FID860559]
Hi Joel,
Thanks for confirming that Suddenlink has no information responsive to Apple's subpoena with the exception of a handful
of technical manuals and a contract with Motorola, which you expect to be produced by Motorola. Based on our
conversation and your representation that no one at Suddenlink has knowledge regarding the software loaded on the set
top boxes provided to you by Motorola, we will not be pursuing further requests from you at this time. As I mentioned on
the phone, however, if it turns out that Motorola does not produce the documents you referenced, we may ask you to
produce copies.
Best regards,
Jill
1
Jill Ho
Weil, Gotshal & Manges LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065-1134
jill.ho@weil.com
+1 650 802 3163 Direct
+1 650 802 3100 Fax
From: Samuels, Joel [mailto:jsamuels@hdp.com]
Sent: Wednesday, November 30, 2011 8:30 AM
To: Ho, Jill
Subject: RE: Motorola v. Apple: Suddenlink Communications Subpoena [HDP-STL_Legal.FID860559]
Jill:
I have talked to my client about this subpoena. Would you please give me a call at your convenience to discuss? I’m
around this morning and early afternoon, but will be unavailable after 2:30pm CST.
Best,
‐ Joel
Joel R. Samuels | Attorney at Law
O | 314.726.7509 F | 314.726.7501
Patent, Trademark & Copyright Law
From: Ho, Jill [mailto:jill.ho@weil.com]
Sent: Tuesday, November 22, 2011 9:38 AM
To: Samuels, Joel
Subject: Re: Motorola v. Apple: Suddenlink Communications Subpoena [HDP-STL_Legal.FID860559]
Thanks, Joel.
From: Samuels, Joel [mailto:jsamuels@hdp.com]
Sent: Tuesday, November 22, 2011 10:32 AM
To: Ho, Jill
Subject: RE: Motorola v. Apple: Suddenlink Communications Subpoena [HDP-STL_Legal.FID860559]
Hi Jill:
Thanks for the extension and the amended subpoena. HDP accepts service on behalf of Suddenlink.
‐ Joel
Joel R. Samuels | Attorney at Law
O | 314.726.7509 F | 314.726.7501
Patent, Trademark & Copyright Law
From: Ho, Jill [mailto:jill.ho@weil.com]
Sent: Monday, November 21, 2011 6:51 PM
To: Samuels, Joel
Subject: RE: Motorola v. Apple: Suddenlink Communications Subpoena [HDP-STL_Legal.FID860559]
2
Hi Joel,
The extension you suggest is fine. Here is an amended subpoena that reflects that date and the correct jurisdiction. Please
let me know immediately if you are not authorized to receive service on behalf of Suddenlink so we can serve this through
formal channels.
Best regards,
Jill
Jill Ho
Weil, Gotshal & Manges LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065-1134
jill.ho@weil.com
+1 650 802 3163 Direct
+1 650 802 3100 Fax
From: Samuels, Joel [mailto:jsamuels@hdp.com]
Sent: Monday, November 21, 2011 3:21 PM
To: Ho, Jill
Subject: Motorola v. Apple: Suddenlink Communications Subpoena [HDP-STL_Legal.FID860559]
Dear Ms. Ho:
It was a pleasure speaking with you this afternoon. I appreciate your willingness to work with Suddenlink regarding the
scope and timeline for Suddenlink’s compliance and objections to the subpoena. As we discussed, due to the impending
holiday, Suddenlink would appreciate a few weeks extension in order to respond to the subpoena. The client informed
me that the responsible members of their IT department will be returning from vacation towards the middle of next
week. Accordingly, Suddenlink proposes Friday, December 16, 2011 as the new deadline for responding to Apple’s
subpoena. Please let me know if this date works for you. As discussed, we will be in contact during the interim period
regarding the scope of the subpoena.
I raised the procedural issue regarding the issuing Court with the client. As I indicated on the phone, due to Apple’s
flexibility, in general, Suddenlink does not view this as a major concern. Nevertheless, should Apple require a
deposition, Suddenlink will request that Apple provide a properly issued subpoena. Finally, in the event you decide that
you will no longer need any information from Suddenlink, we would appreciate prompt notice.
Thank you again for your consideration. If you have any questions, please call me at 314.726.7509.
Sincerely,
Joel R. Samuels
Office: 314.726.7509
Joel R. Samuels
Fax:
314.726.7501
Attorney at Law
7700 Bonhomme, Suite 400
St. Louis, MO 63105
Patent, Trademark & Copyright Law
Bio vCard
3
Metropolitan | Detroit Portland St. Louis Washington, DC
HARNESS, DICKEY & PIERCE, PLC LEGAL NOTICE: The information contained in this transmission is intended only for the individual(s) or entity(ies) to
whom it is addressed. It may contain information protected from use and/or disclosure by law, including information that is protected as confidential, attorney-client
privileged, attorney work product and/or trade secrets. If the reader of this message is not the intended recipient, or an employee or agent responsible for
delivering this message to the addressee, the reader is hereby notified that any use, distribution or copying of this communication is strictly prohibited. If you
believe you have received this facsimile or message in error, please immediately notify us at our expense by return mail or e-mail and permanently delete or
destroy all copies of the message.
To comply with U.S. Treasury regulations, we advise you that any discussion of Federal tax issues in this communication was not intended to be used, and cannot
be used, by any person (i) to avoid penalties that may be imposed by the Internal Revenue Service, or (ii) to promote, market or recommend to another party any
matter addressed herein.
Any portions of this transmission containing controlled technical data are restricted by U.S. export laws and regulations, and may not be distributed or
retransmitted to non-U.S. persons without appropriate licensing or a licensing exemption. Neither this information block, nor the signature block, nor the typed
name of the sender, nor anything else in this message is intended to constitute an electronic signature unless a specific statement to the contrary is included.
The information contained in this email message is intended only for use of the individual or entity named above. If the
reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended
recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly
prohibited. If you have received this communication in error, please immediately notify us by email, postmaster@weil.com,
and destroy the original message. Thank you.
4
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?