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 K
Ho, Jill
From:
Sent:
To:
Subject:
Harrison, Cody
Wednesday, November 30, 2011 12:01 PM
Ho, Jill
RE: Bright House Networks
Thanks, Jill. This is all I need. Just want to make sure we agree no obligation to do anything now.
Regards,
CJH
From: Ho, Jill [mailto:jill.ho@weil.com]
Sent: Wednesday, November 30, 2011 2:39 PM
To: Harrison, Cody
Subject: RE: Bright House Networks
Hi Cody,
I just left you a voicemail. Given our close of discovery in the middle of January, I cannot agree to withdraw Apple's
subpoena because there will not be enough time for us to serve a new one if it turns out Motorola does not produce the
discovery we need. That said, as I confirmed during our conversation the other day, we would prefer to get discovery
from Motorola rather than bother any third-parties, so we do not plan to actively pursue further information from you at
this time. If we can let the subpoena sit as a placeholder, I should be able to confirm whether we need any discovery from
Bright House after we see what Motorola produces. I'm happy to agree to an extension on Bright House's objections, if
needed.
Please give me a call if you'd like to discuss.
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: Harrison, Cody [mailto:CHarrison@sabinfirm.com]
Sent: Wednesday, November 30, 2011 8:06 AM
To: Ho, Jill
Subject: Bright House Networks
Jill,
1
This is to confirm our conversation that Apple, Inc. will not presently pursue the two third‐party subpoenas issued to
Bright House Networks by the U.S. District Courts in the Eastern District of Pennsylvania and the Middle District of New
York, and that Bright House has no obligation to respond to those subpoenas. We ask that Apple withdraw the two
subpoenas, with the understanding that it may obtain new subpoenas should it seek information from Bright House in
the future. I am also sending to your attention the two $40 subpoena processing checks.
Feel free to give me a call if needed.
CJH
Cody J. Harrison
Four Times Square
New York, NY 10036
tel. 212-381-7117
fax 212-381-7218
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