Li v. Apple Inc. et al

Filing 33

Letter to Judge Wexler responding to Plaintiff's January 29 letter and confirming that motions to dismiss will be served pursuant to previous schedule by Apple Inc., Steve Jobs (Miller, Michael)

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Li v. Apple Inc. et al Doc. 33 1290 AVENUE OF THE AMERICAS NEW YORK, NY 10104-0050 TELEPHONE: 212.468.8000 FACSIMILE: 212.468.7900 WWW.MOFO.COM MO RRI SO N & F O E RST E R L LP N E W YO RK , SAN F RAN C I SCO , L O S A N G E L E S, P A L O A L T O , SAN D I E G O , WASH I N G T O N , D .C . N O RT H E RN VI RG I N I A, O RAN G E C O U N T Y, D E N VE R, SAC RAME N T O , WAL N U T C RE E K T O K YO , LO N D O N , BE I JI N G , SH AN G H AI , H O N G K O N G , SI N G A P O R E , BRU SSE L S January 30, 2008 Writer's Direct Contact 212.468.8009 MBMiller@mofo.com Hon. Leonard D. Wexler United States District Court Eastern District of New York 100 Federal Plaza Central Islip, NY 11722 Re: Li v. Apple Inc., et al., Case No. CF-07-04005 (LDW)(ETB) Dear Judge Wexler: We represent defendants Apple Inc. and Steve Jobs in the above-captioned action, and write this letter on behalf of all defendants, including AT&T Inc. Although your Honor's Individual Practices do not permit "reply" submissions in connection with letters requesting a pre-motion conference, counsel for plaintiff submitted such a letter yesterday via the ECF system. Defendants disagree with the various assertions contained in that letter, but will not respond to them by "sur-reply" unless such a response is requested by the Court. As provided for in your Honor's Order of January 14 and the Proposed Scheduling Order that was submitted to the Court on January 18, the defendants in this case will serve their motions to dismiss the entire Complaint in this action on January 31. Respectfully submitted, /s/ Michael B Miller Michael B. Miller cc: All Counsel (Via ECF) ny-797817 Dockets.Justia.com

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