Motorola Mobility, Inc. v. Apple, Inc.

Filing 307

MOTION for Leave to File Surreply by Motorola Mobility, Inc.. (Attachments: # 1 Exhibit A- Surreply, # 2 Affidavit of John Duchemin in Support of Motorola's Surreply, # 3 Text of Proposed Order Granting Motorola's Motion for Leave to File Surreply)(Herrera, Sujey)

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 JOHN DUCHEMIN IN SUPPORT OF MOTOROLA’S SURREPLY
REGARDING APPLE’S MOTION TO COMPEL
FURTHER SUPPLEMENTAL RESPONSES TO INTERROGATORY NOS. 19-22

CASE NO. 1:10cv023580-Civ-RNS-TEB
I, John Duchemin, 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.

Attached as Exhibit 1 is a true and correct copy of Apple’s Supplemental

Objections and Responses to Motorola Mobility and Motorola's First Set of Interrogatories (No.
6). On page 4 of these contentions, Apple lists twenty-seven Accused Set-Top Boxes. None of
these Accused Products is a remote control.
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 April 2012 at Redwood Shores,
California.

/s/ John Duchemin
John Duchemin

2

EXHIBIT 1
FILED UNDER SEAL