Motorola Mobility, Inc. v. Apple, Inc.

Filing 342

RESPONSE to Motion re 333 Plaintiff's MOTION to Enforce Order Compelling Rule 30(b)(6) Deposition Testimony from Apple and Accompanying Memorandum of Law in Support Apple's Response to Motorola's Motion to Enforce Order Compelling Rule 30(b)(6) Deposition Testimony From Apple filed by Apple, Inc.. Replies due by 5/11/2012. (Attachments: # 1 Affidavit Declaration of Christine Saunders Haskett, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6)(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,
v.

JURY TRIAL DEMANDED

APPLE INC.,
Defendant.

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

DECLARATION OF CHRISTINE SAUNDERS HASKETT IN SUPPORT OF
APPLE’S RESPONSE TO
MOTOROLA’S MOTION TO ENFORCE ORDER COMPELLING RULE 30(b)(6)
DEPOSITION TESTIMONY FROM APPLE

I, Christine Saunders Haskett, hereby declare:
I am a member of the law firm of Covington & Burling LLP, counsel of record for Apple
Inc. in the above-captioned matter. The matters referenced in this declaration are based on
personal knowledge and if called as a witness I could, and would, testify competently to these
matters.
1.

Attached hereto as Exhibit 1 is a true and correct copy of an email dated April 3,

2012 from me to counsel for Motorola, Matt Korhonen and Greg Bonifield.
2.

Attached hereto as Exhibit 2 is a true and correct copy of an email dated April 10,

2012 from counsel for Motorola, Marshall Searcy, to counsel for Apple, Anne Cappella.
3.

Attached hereto as Exhibit 3 is a true and correct copy of an email dated April 16,

2012 from counsel for Motorola, Greg Bonifield, to me.
4.

Attached hereto as Exhibit 4 is a true and correct copy of an email dated April 19,

2012 from counsel for Motorola, Greg Bonifield, to me.
5.

Attached hereto as Exhibit 5 is a true and correct copy of an email dated

December 7, 2011 from counsel for Apple, Jill Ho, to counsel for Motorola, Ben Quarmby.
6.

Attached hereto as Exhibit 6 is a true and correct copy of an email dated April 20,

2012 from me to counsel for Motorola, Greg Bonifield.

I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct to the best of my knowledge and belief.
Executed on May 1, 2012 at San Francisco, California.
/s/ Christine Saunders Haskett
CHRISTINE SAUNDERS HASKETT

1