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)

EXHIBIT 3

From:
Sent:
To:
Cc:
Subject:

Greg Bonifield <[e-mail]>
Monday, April 16, 2012 6:56 AM
Haskett, Christine; AppleCov; Apple Moto Weil
Lopez, Tony; Moto-Apple-SDFL
RE: Motorola v. Apple depositions (Florida)

Christine,
With respect to the depositions ordered by the Court in its Order entered March 30, Apple has not provided an updated
deposition date for Phil Peterson for the 30(b)(6) deposition regarding the source code for the webmail functionality of
Apple’s accused MobileMe product, and has not provided a date or a witness for the 30(b)(6) deposition regarding the
email notification function for iOS 5. When we discussed these depositions on the phone the week before last, I
requested that Apple schedule them for either this week or next week, the week of April 23. Please give us dates next
week for both of these depositions ASAP.
Regards,
Greg
From: Haskett, Christine [mailto:[e-mail]]
Sent: Tuesday, April 03, 2012 6:50 PM
To: Matt Korhonen; Greg Bonifield
Cc: Lopez, Tony
Subject: Motorola v. Apple depositions (Florida)

Matt and Greg,
Following up on the court’s order of last Friday, Phil Peterson is available for a deposition
regarding the webmail source code governing MobileMe Rules on Monday, April 9th, starting
at 1:00 p.m. Mr. Peterson’s schedule is very busy, so if it’s possible for you to confirm this
date today, that would be much appreciated.
Christine
Christine Saunders Haskett | COVINGTON & BURLING LLP
One Front Street, San Francisco, CA 94111
Tel: [phone] | Fax: [phone]
[e-mail] | www.cov.com

This message is from a law firm and may contain information that is confidential or legally privileged. If
you are not the intended recipient, please immediately advise the sender by reply e-mail that this
message has been inadvertently transmitted to you and delete this e-mail from your system. Thank you
for your cooperation.

1