Motorola Mobility, Inc. v. Apple, Inc.
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)
Thursday, August 02, 2012 8:01 PM
Marshall Searcy; Moto-Apple-SDFL (Moto-Apple-SDFL@quinnemanuel.com)
Weil TLG Apple Moto FL External
Apple/Motorola (FL): meet and confer
I write to memorialize our meet and confer from earlier today. With respect to document production, we agreed that
Apple will produce its documents as OCR’ed pdfs and Motorola will produce its documents as single‐page TIFFs, but both
sides will simply keep their copies of documents produced in the FL‐1 action rather than re‐producing everything
again. Since Motorola did not previously specify which documents it produced for the FL‐1 action with a different prefix,
please identify those documents by Bates range. As for metadata fields, Apple would prefer to stick with the same fields
as the other Apple/Motorola cases if HTC is no longer involved. With respect to documents produced in other
Apple/Motorola cases, Apple is amenable to extending our cross‐use agreement. You are double‐checking with your
team and will get back to me with any objections.
With regard to discovery limits, we agreed that the following limits would apply to the consolidated FL cases, with the
understanding that either party may serve discovery (within these limits) that pertain to patents asserted in the FL‐1
action as well as the FL‐2 action:
90 hours of deposition for fact/30(b)(6) witnesses (experts or third‐party witnesses do not count towards
As for our agreement regarding unreleased products, we agreed that we likely need to craft a new agreement for the
consolidated FL cases since my recollection was that our previously agreed cutoff date was the 745 trial and both Apple
and Motorola have already accused products released since that date.
Finally, on financial data, we agreed in principle that an exchange of representative or summary data would be more
efficient for both sides. We agreed to check with our respective teams to see what exchange was made in the NDIL
case, so we can use that as a starting point for further discussions.
Please let me know if scheduling another call for early next week would be useful.
Jill Schmidt (née Ho)
Weil, Gotshal & Manges LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065-1134
+1 650 802 3163 Direct
+1 650 802 3100 Fax
From: Marshall Searcy [mailto:firstname.lastname@example.org]
Sent: Thursday, August 02, 2012 10:21 AM
To: Schmidt, Jill
Subject: conference call number
Here’s the number for today
Speak to you at 11.
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