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 O
Ho, Jill
From:
Sent:
To:
Cc:
Subject:
Ho, Jill
Monday, December 26, 2011 12:16 PM
'marshallsearcy@quinnemanuel.com'; 'DavidElihu@quinnemanuel.com';
'benquarmby@quinnemanuel.com'; 'Moto-Apple-SDFL@quinnemanuel.com'
Weil_TLG Apple Moto FL External; 'AppleCov@cov.com'
RE: Apple/Motorola (FL): supplementation of interrogatory responses
Hi Marshall,
Apple proposes January 6 for the exchange of supplemental interrogatory responses. Please confirm that Motorola will
also be supplementing its responses to Apple's third set of interrogatories at that time.
Thanks,
Jill
From: Ho, Jill
Sent: Wednesday, December 21, 2011 4:14 PM
To: marshallsearcy@quinnemanuel.com; DavidElihu@quinnemanuel.com; benquarmby@quinnemanuel.com; Moto-AppleSDFL@quinnemanuel.com
Cc: Weil_TLG Apple Moto FL External; AppleCov@cov.com
Subject: Re: Apple/Motorola (FL): supplementation of interrogatory responses
Hi Marshall,
Just confirming our conversation that, although Apple is ready to supplement our interrogatory responses and Motorola
is partially ready to supplement its responses, neither side will be serving supplemental responses tonight.
You have requested that we pick a new date for mutual exchange of our supplemental interrogatory responses
approximately 2‐3 weeks from now. I requested that Motorola add responses to Apple's third set of interrogatories to its
list of responses to supplement. I will touch base with you early next week, after circling back with the team, to confirm
a date that would be agreeable to us.
Please let me know if I have misunderstood our agreement.
Happy holidays,
Jill
From: Marshall Searcy [mailto:marshallsearcy@quinnemanuel.com]
Sent: Wednesday, December 21, 2011 06:20 PM
To: Ho, Jill; David Elihu ; Ben Quarmby ; MotoApple-SDFL
Cc: Weil_TLG Apple Moto FL External; AppleCov@cov.com
Subject: RE: Apple/Motorola (FL): supplementation of interrogatory responses
Hi Jill,
I can be available for a call. Let me know what time works for you.
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From: Ho, Jill [mailto:jill.ho@weil.com]
Sent: Wednesday, December 21, 2011 3:00 PM
To: David Elihu; Ben Quarmby; Moto-Apple-SDFL
Cc: Weil_TLG Apple Moto FL External; AppleCov@cov.com; Marshall Searcy
Subject: Re: Apple/Motorola (FL): supplementation of interrogatory responses
Hi David,
I am in transit at the moment, but are you available for a call in another hour or so?
Best regards,
Jill
From: David Elihu [mailto:DavidElihu@quinnemanuel.com]
Sent: Wednesday, December 21, 2011 05:37 PM
To: Ho, Jill; Ben Quarmby ; Moto-Apple-SDFL
Cc: Weil_TLG Apple Moto FL External; 'AppleCov@cov.com' ; Marshall Searcy
Subject: RE: Apple/Motorola (FL): supplementation of interrogatory responses
Jill,
We will be providing supplemental responses today to Apple’s Interrogatory Nos. 3, 8 and 13. Motorola responded to
Interrogatory Nos. 20 and 22 on Monday. For the remaining interrogatories, Apple’s Interrogatory Nos. 1, 7, 9, 11, and
12, we are continuing to work on our responses. We suggest that the parties meet and confer to discuss new dates, in
view of the new case schedule, by which to exchange supplemental responses on these interrogatories. To the extent
that Apple wishes to take additional time to supplement its responses to Motorola’s Interrogatories, we are of course
agreeable to this.
Regards,
David
David Elihu
Associate,
Quinn Emanuel Urquhart & Sullivan, LLP
51 Madison Avenue, 22nd Floor
New York, NY 10010
212-849-7285 Direct
212.849.7000 Main Office Number
212.849.7100 FAX
DavidElihu@quinnemanuel.com
www.quinnemanuel.com
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From: Ho, Jill [mailto:jill.ho@weil.com]
Sent: Wednesday, December 14, 2011 7:50 PM
To: Ben Quarmby; Moto-Apple-SDFL
Cc: Weil_TLG Apple Moto FL External; 'AppleCov@cov.com'; Marshall Searcy
Subject: Apple/Motorola (FL): supplementation of interrogatory responses
Hi Ben,
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Per your request, I write to confirm our understanding that the parties are supplementing their responses for the
interrogatories identified in your letter of November 21, 2011. These are: Motorola's Interrogatory Nos. 1, 3, 5, 8, 9, &
11-15 and Apple's Interrogatory Nos. 1, 3, 7, 9, 11-13, 20, & 22.
Also, Apple agrees to Motorola's proposed extension of the date by which the parties will exchange these supplemental
responses from Friday, December 16 to Wednesday, December 21.
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
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