Motorola Mobility, Inc. v. Apple, Inc.

Filing 276

NOTICE by Apple, Inc. of Filing Declaration of Jill J. Ho in Support of Apple Inc.'s Motion for Leave to File Amended Answer and Exhibits Thereto (Attachments: # 1 Affidavit Declaration of Jill J. Ho in Support of Apple Inc.'s Motion for Leave to File Amended Answer, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S)(Pace, Christopher)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No. 1:10cv023580-Civ-RNS-TEB

MOTOROLA MOBILITY, INC.,
Plaintiff,

JURY TRIAL DEMANDED

v.
APPLE INC.,
Defendant.
APPLE INC.,
Counterclaim Plaintiff,
v.
MOTOROLA, INC. and
MOTOROLA MOBILITY, INC.,
Counterclaim Defendants.

DECLARATION OF JILL J. HO IN SUPPORT OF APPLE INC.’S
MOTION FOR LEAVE TO FILE AMENDED ANSWER

I, Jill J. Ho,1 declare under penalty of perjury, that the following is true and
correct:
1.

I am a member of the bar of the State of California, admitted pro hac vice in this

action and an associate at the law firm of Weil, Gotshal & Manges LLP, counsel of
record for Apple Inc. (“Apple”) in the above-captioned matter. The matters referred to in
this declaration are based on personal knowledge and if called as a witness I could, and
would, testify competently to these matters.
2.

Attached hereto as Exhibit A is a true and correct copy of Apple’s proposed

Second Amended Answer.
3.

Attached hereto as Exhibit B is a true and correct copy of a March 9, 2012 email

from me to Cathleen Garrigan of Quinn Emanuel Urqhart & Sullivan, LLP.
4.

Attached hereto as Exhibit C is a true and correct copy of a March 12, 2012 email

from me to Ms. Garrigan. Attached hereto as Exhibit D is a true and correct copy of the
redlined copy of Apple’s proposed amended pleading which was attached to that email.
5.

Attached hereto as Exhibit E is a true and correct copy of a March 14, 2012 email

from Ms. Garrigan to me.
6.

Attached hereto as Exhibit F is a true and correct copy of a March 19, 2012 email

from me to Ms. Garrigan.
7.

Attached hereto as Exhibit G is a true and correct copy of Motorola Mobility’s

Responses to Apple’s Third Set of Interrogatories to Motorola Mobility and Motorola
(Nos. 16-22), served on December 19, 2011.
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Jill Ho is currently in the process of adopting her married name, Jill Schmidt.

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8.

Attached hereto as Exhibit H is a true and correct copy of Apple’s subpoena to

third-party Bright House Networks, LLC.
9.

Attached hereto as Exhibit I is a true and correct copy of Apple’s subpoena to

third-party Cablevision Systems Corporation.
10.

Attached hereto as Exhibit J is a true and correct copy of Apple’s subpoena to

third-party Charter Communications, Inc.
11.

Attached hereto as Exhibit K is a true and correct copy of Apple’s subpoena to

third-party Comcast Corporation.
12.

Attached hereto as Exhibit L is a true and correct copy of Apple’s subpoena to

third-party Cox Communications, Inc.
13.

Attached hereto as Exhibit M is a true and correct copy of Apple’s subpoena to

third-party Mediacom Communications Corporation.
14.

Attached hereto as Exhibit N is a true and correct copy of Apple’s subpoena to

third-party Suddenlink Communications.
15.

Attached hereto as Exhibit O is a true and correct copy of Apple’s subpoena to

third-party Time Warner Cable, Inc.
16.

Attached hereto as Exhibit P is a true and correct copy of Apple’s subpoena to

third-party Verizon Services Corporation.
17.

Attached hereto as Exhibit Q is a true and correct copy of Apple’s First Set of

Requests for Production to Motorola Mobility and Motorola (Nos. 1-49), served on
December 29, 2010.

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18.

Attached hereto as Exhibit R is a true and correct copy of Apple’s Third Set of

Interrogatories to Motorola Mobility and Motorola (Nos. 16-22), served on November 14,
2011.
19.

Attached hereto as Exhibit S is a true and correct copy of Apple’s Notice of

Deposition of Motorola Mobility, Inc., served on June 24, 2011.
20.

Attached hereto as Exhibit T is a true and correct copy of the transcript from the

deposition of Evan Groat, taken on February 28, 2012.
21.

Attached hereto as Exhibit U is a true and correct copy of the transcript from the

deposition of Richard Rementilla, taken on March 16, 2012.
22.

Attached hereto as Exhibit V is a true and correct copy of a March 14, 2012 email

from Amanda Williamson of Quinn Emanuel Urqhart & Sullivan, LLP to my colleague
Sutton Ansley, cc’ing a service list of which I am a member.

I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.
Executed on March 23, 2012 at Redwood Shores, California
/s/ Jill J. Ho
Jill J. Ho

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