Motorola Mobility, Inc. v. Apple, Inc.

Filing 281

NOTICE by Apple, Inc. Notice of Filing of Declaration of Jill J. Ho in Support of Apple Inc.'s Motion to Compel Further Responses to Interrogatories Regarding Set-Top Box Patents (Nos. 19-22) and Exhibits Thereto (Attachments: # 1 Affidavit Declaration of Jill J. Ho in Support of Apple's Motion to Compel Further Responses to Interrogatories Regarding Set-Top Box Patents (Nos. 19-22), # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit I, # 4 Exhibit Exhibit J, # 5 Exhibit Exhibit K, # 6 Exhibit Exhibit L)(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 TO
COMPEL FURTHER RESPONSES TO INTERROGATORIES REGARDING
SET-TOP BOX PATENTS (NOS. 19-22)

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 Motorola Mobility’s

Second Supplemental Responses to Apple’s Third Set of Interrogatories to Motorola
Mobility and Motorola (Nos. 19-22), served on March 9, 2012.
3.

Attached hereto as Exhibit B is a true and correct copy of Apple’s infringement

contentions, styled as Apple’s Supplemental Objections and Responses to Motorola
Mobility and Motorola’s First Set of Interrogatories (No. 6), served on May 18, 2011.
The appended infringement charts were previously filed on October 28, 2011. See D.E.
161.
4.

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

from my colleague Jason Lang to John Duchemin of Quinn Emanuel Urqhart & Sullivan,
LLP.
5.

Attached hereto as Exhibit D is a true and correct copy of a March 13, 2012 email

from Mr. Duchemin to Mr. Lang.
6.

Attached hereto as Exhibit E is a true and correct copy of a March 15, 2012 email

from Mr. Duchemin to Mr. Lang.
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Jill Ho is currently in the process of adopting her married name, Jill Schmidt.

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7.

Attached hereto as Exhibit F is a true and correct copy of a March 22, 2012 email

from Mr. Duchemin to Mr. Lang.
8.

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

deposition of Evan Groat, taken on February 28, 2012.
9.

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

deposition of Richard Rementilla, taken on March 16, 2012.
10.

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

Deposition of Motorola Mobility, Inc., served on June 24, 2011.
11.

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

Deposition of Motorola Mobility, Inc., served on February 1, 2012.
12.

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

of Deposition of Motorola Mobility, Inc., served on February 8, 2012.
13.

Attached hereto as Exhibit L is a true and correct copy of a November 14, 2011

letter from David Perlson of Quinn Emanuel Urqhart & Sullivan, LLP to me.
14.

Attached hereto as Exhibit M is a true and correct copy of a document produced

by Motorola, bearing the Bates number MOTO-APPLE-0007423455.xls.

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 26, 2012 at Redwood Shores, California
/s/ Jill J. Ho
Jill J. Ho

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