Motorola Mobility, Inc. v. Apple, Inc.

Filing 230

RESPONSE in Opposition re 225 MOTION to Compel Responses to Interrogatories Nos. 7 and 12 Regarding Products Embodying Motorola's Asserted Patents and Accompanying Memorandum of Law in Support filed by Motorola Mobility, Inc.. (Attachments: # 1 Affidavit of David M. Elihu, # 2 Exhibit A to Declaration (redacted), # 3 Exhibit B to Declaration, # 4 Exhibit C to Declaration, # 5 Exhibit D to Declaration)(Escobar, Annette)

Exhibit C

Graham Pechenik
From:
Sent:
To:
Subject:

Matt Korhonen
Friday, February 03, 2012 8:04 PM
Graham Pechenik
FW: Motorola v. Apple (SDFL): Mobility discovery responses

From: Marshall Searcy
Sent: Thursday, January 19, 2012 9:50 PM
To: 'DiMuzio, Elena'
Cc: 'Ho, Jill'; 'AppleCov'; '[e-mail]'; '[e-mail]';
'Apple Moto Weil'; '[e-mail]'; Moto-Apple-SDFL
Subject: RE: Motorola v. Apple (SDFL): Mobility discovery responses

Elena,
Motorola’s position with regard to Interrogatory No. 12 continues to be the same as we discussed in December. We
believe Interrogatory No. 12 seeks irrelevant information, and would impose an undue and unnecessary burden on
Motorola. And while, as I stated in my December 23 e-mail on the subject, Motorola is open to further suggestions on
dealing with these problems, at this point they haven’t been addressed and we do not intend to supplement.
From: DiMuzio, Elena [mailto:[e-mail]]
Sent: Thursday, January 19, 2012 2:45 PM
To: Marshall Searcy
Cc: Ho, Jill; AppleCov; [e-mail]; [e-mail]; Apple
Moto Weil; [e-mail]; Moto-Apple-SDFL
Subject: RE: Motorola v. Apple (SDFL): Mobility discovery responses

Marshall,
I understand that in the meet-and-confer yesterday you stated that Motorola does not intend to supplement its current
response to Interrogatory 12. Please confirm. If this is Motorola’s position, we will be addressing this in our motion to
compel Motorola’s response to Interrogatory 12.
Best Regards,
Elena.
From: Ho, Jill [mailto:[e-mail]]
Sent: Tuesday, January 17, 2012 6:30 PM
To: Cathleen Garrigan; AppleCov; [e-mail];
[e-mail]; Apple Moto Weil; [e-mail]; Moto-Apple-SDFL
Subject: RE: Motorola v. Apple (SDFL): Mobility discovery responses

Hi Cathleen,
Based on my agreement with Ben, as documented in his November 21, 2011 letter and as modified by
subsequent discussions with you and Marshall, we were expecting Motorola to supplement its responses for
Interrogatory Nos. 1, 3, 7, 9, 11-13, and 16-22 by today. (Indeed, our original agreement was to exchange
responses over a month ago, on December 16.) It appears, however, that Motorola only served supplemental
interrogatory responses for Nos. 1, 3, 9, 11, 16 and 17.

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Please let me know when you are available to meet and confer about this issue tomorrow.
Best regards,
Jill
From: Cathleen Garrigan [mailto:[e-mail]]
Sent: Tuesday, January 17, 2012 6:02 PM
To: AppleCov; [e-mail]; [e-mail]; Apple
Moto Weil; [e-mail]; Moto-Apple-SDFL
Subject: Motorola v. Apple (SDFL): Mobility discovery responses

Jill,
Please see the attached documents.
Best,
Cathleen

Cathleen Garrigan
Associate,

Quinn Emanuel Urquhart & Sullivan, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
415-875-6341 Direct
415.875.6600 Main Office Number
415.875.6700 FAX
[e-mail]
www.quinnemanuel.com
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