Motorola Mobility, Inc. v. Apple, Inc.

Filing 361

MOTION to Amend/Correct (84 in 1:12-cv-20271-RNS) Scheduling Order,,, MEMORANDUM OF LAW AND MOTION TO AMEND THE PROCEDURAL SCHEDULE by Apple Inc.. Responses due by 10/29/2012 (Attachments: # 1 Text of Proposed Order, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11)Associated Cases: 1:12-cv-20271-RNS, 1:10-cv-23580-RNS(Pace, Christopher)

EXHIBIT 2

BY E-MAIL

September 5, 2012

1300 Eye Street NW, Suite 900
Washington, DC 20005-3314
[phone] tel
[phone] fax
Robert T. Vlasis
[phone]
[e-mail]

Marshall M. Searcy III
Quinn Emanuel Urquhart & Sullivan, LLP
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017

Re: Motorola Mobility, Inc. v. Apple Inc., Consolidated Case Nos. 1:10-cv-23580-RNS and 1:12-cv20271-RNS (S.D. Fla.)
Dear Marshall,
Apple requested to meet and confer with Motorola on Friday, August 31, and again on Tuesday,
September 4, concerning the parties’ ongoing negotiations to set a framework that limits adding new
products to the case. We have received no response to either request. We are generally available on
Thursday and Friday of this week to continue this discussion. Please let us know a specific day and time
that is convenient for you, and please be prepared to state Motorola’s position.
Additionally, in Motorola’s Responses and Objections to Apple’s Second Set of Requests for
Production (Nos. 61-69), Motorola requested a meet-and-confer for all but one request. Accordingly,
please provide a date when Motorola is available to meet and confer about Request Nos. 61-66 and 6869.
Best regards,
/s/ Robert Vlasis
Robert T. Vlasis