Motorola Mobility, Inc. v. Apple, Inc.

Filing 260

MOTION to Compel Rule 30(b)(6) Deposition Testimony From Apple by Motorola Mobility, Inc.. Responses due by 3/26/2012 (Attachments: # 1 Affidavit M. Korhonen, # 2 Affidavit C. Garrigan, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I)(Escobar, Annette)

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 1:10cv023580-Civ-RNS-TEB MOTOROLA MOBILITY, INC., Plaintiff, v. JURY TRIAL DEMANDED APPLE INC., Defendant. APPLE INC., Counterclaim Plaintiff, v. MOTOROLA, INC. and MOTOROLA MOBILITY, INC., Counterclaim Defendants. DECLARATION OF MATTHEW O. KORHONEN IN SUPPORT OF MOTOROLA’S MOTION TO COMPEL RULE 30(b)(6) DEPOSITION TESTIMONY FROM APPLE 1 I, Matthew O. Korhonen, declare: I am a member of the bar of the State of California, admitted pro hac vice in this action and an associate with Quinn Emanuel Urquhart & Sullivan, LLP, attorneys for Motorola Mobility, Inc. and Motorola Solutions, Inc. (f/k/a Motorola, Inc.) (collectively "Motorola"). I make this declaration of personal, firsthand knowledge, and if called and sworn as a witness, I could and would testify competently to the matters contained in this declaration. 1. On February 1, counsel for Motorola notified counsel for Apple that Apple failed to produce source code relating to MobileMe Rules functionality. On February 3 and February 6, counsel for Apple and counsel for Motorola met and conferred regarding Apple's failure to produce this source code. On February 7, Apple notified Motorola that it had made the MobileMe Rules functionality source code available for inspection. 2. On February 24, 2012, counsel for Apple and counsel for Motorola met and conferred regarding Apple's to provision of a Rule 30(b)(6) witness prepared to testify regarding the email notifications on devices running iOS 5 and Apple's provision of a Rule 30(b)(6) witness on Apple's MobileMe webmail source code. At the February 24, 2012 meet and confer, Apple maintained its position that it would not provide a 30(b)(6) witness on either topic. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 9th day of March 2012 at Miami, Florida. Matthew O. Korhonen 2

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