Motorola Mobility, Inc. v. Microsoft Corporation

Filing 74

RESPONSE in Opposition re #62 Defendant's MOTION to Change Venue Defendant's Motion to Transfer This Action to the Western District of Washington and Accompanying Memorandum of Law filed by Motorola Mobility, Inc.. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit, #9 Exhibit, #10 Exhibit, #11 Exhibit, #12 Exhibit, #13 Exhibit, #14 Exhibit, #15 Exhibit, #16 Exhibit, #17 Exhibit, #18 Exhibit, #19 Exhibit, #20 Exhibit, #21 Exhibit, #22 Exhibit, #23 Exhibit, #24 Exhibit, #25 Exhibit, #26 Exhibit, #27 Exhibit, #28 Affidavit, #29 Affidavit, #30 Affidavit)(Giuliano, Douglas)

EXHIBIT H

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
CASE NO. 1:10-CV-24063-MORENO/BROWN
)
)
)
Plaintiff/Counterclaim Defendant, )
)
v.
)
)
MICROSOFT CORPORATION,
)
Defendant/Counterclaim Plaintiff. )
)
)
MOTOROLA MOBILITY, INC.,

PLAINTIFF MOTOROLA MOBILITY, INC.’S NOTICE OF
SUBPOENA TO THIRD PARTY ERIC THOMAS EATON
PLEASE TAKE NOTICE that pursuant to Rules 30(a)(1), 34(c), and 45 of the Federal
Rules of Civil Procedure, Plaintiff Motorola Mobility, Inc. (“Motorola Mobility”) served the
subpoena attached as Exhibit 1 on Eric Thomas Eaton.
The documents set forth in Schedule A attached thereto are to be produced on or before
June 8, 2011 at 5:00 pm Eastern Time at the offices of Astigarraga Davis Mullins & Grossman,
P.A., 701 Brickell Avenue, 16th Floor, Miami, FL 33131.
PLEASE TAKE FURTHER NOTICE that Motorola Mobility, by and through its
attorneys Ropes & Gray LLP, will take the deposition upon oral examination of Mr. Eaton on
June 14, 2011 at 9:30 am Eastern Time at the office of Astigarraga Davis Mullins & Grossman,
P.A., 701 Brickell Avenue, 16th Floor, Miami, FL 33131. The deposition will be recorded by
stenographic and/or video means, taken before a Notary Public or other officer authorized by law
to administer oaths, and will continue from day to day until completed.
Respectfully submitted,

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Dated: May 31, 2011

By: /s/ Leslie M. Spencer___
Jesse J. Jenner
Steven Pepe
Khue V. Hoang
Leslie M. Spencer
Ropes & Gray LLP
1211 Avenue of the Americas
New York, NY 10036
Telephone: [phone]
Norman H. Beamer
Mark D. Rowland
Gabrielle E. Higgins
Ropes & Gray LLP
1900 University Avenue, 6th Floor
East Palo Alto, CA 94303
Telephone: [phone]
Kevin J. Post
Megan F. Raymond
Ropes & Gray LLP
One Metro Center
700 12th Street NW, Suite 900
Washington, DC 20005
Telephone: [phone]
Edward M. Mullins
Hal M. Lucas
Astigarraga Davis Mullins & Grossman, P.A.
701 Brickell Avenue, 16th Floor
Miami, Florida 33131
Telephone: [phone]
Attorneys for Plaintiff / Counterclaim Defendant
MOTOROLA MOBILITY, INC.

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CERTIFICATE OF SERVICE
I hereby certify that on May 31, 2011, copies of the foregoing Plaintiff Motorola
Mobility, Inc.’s Notice Of Subpoena To Third Party Eric Thomas Eaton was served by e-mail
upon the counsel of record included in the attached Service List.
/s/ Leslie M. Spencer___
Leslie M. Spencer

SERVICE LIST
Motorola Mobility, Inc. v. Microsoft Corp., Case No. 1:10-cv-24063-MORENO
Roberto Martinez, Esq.
Curtis Miner, Esq.
COLSON HICKS EIDSON
255 Alhambra Circle, 2nd Floor
Coral Gables, Florida 33134
Tel: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendant /
Counterclaim Plaintiff
MICROSOFT CORPORATION
Of Counsel:
David T. Pritikin
Richard A. Cederoth
Douglas I. Lewis
John W. McBride
SIDLEY AUSTIN LLP
One South Dearborn
Chicago, IL 60603
Tel: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]

Brian R. Nester
Kevin C. Wheeler
SIDLEY AUSTIN LLP
1501 K Street NW
Washington, DC 20005
Tel: [phone]
Email: [e-mail]
[e-mail]

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