Apple, Inc. v. Motorola, Inc. et al

Filing 156

Declaration of Samuel F. Ernst filed by Plaintiffs Apple, Inc., Next Software, Inc. re: 154 Motion to Stay (Attachments: # 1 Ex. 1, Part 1 - Agreement and Plan of Merger, # 2 Ex. 1, Part 2 - Agreement and Plan of Merger, # 3 Ex. 1, Part 3 - Agreement and Plan of Merger, # 4 Ex. 1, Part 4 - Agreement and Plan of Merger, # 5 Ex. 1, Part 5 - Agreement and Plan of Merger, # 6 Ex. 2, Supercharging Article, # 7 Ex. 3, M&A Call transcript, # 8 Ex. 4, Letter to Counsel, # 9 Ex. 5, Letter to Counsel, # 10 Ex. 6, Google's Motion to Dismiss, # 11 Ex. 7, Email to Counsel, # 12 Ex. 8, Email to Counsel) (Ernst, Samuel)

EXHIBIT 8

From: Amanda Williamson [mailto:[e-mail]]
Sent: Tuesday, September 06, 2011 4:43 PM
To: Eppich, Christopher K
Cc: Haskett, Christine; Ernst, Samuel
Subject: RE: Apple Inc. et al. v. Motorola, Inc. et al., Case No. 10-cv-662-bbc (W.D. Wis.)

Chris,
As I explained during our teleconference on September 1, 2011, Motorola's production of documents is
ongoing. Mobility is investigating your August 23, 2011, requests for supplementation and will produce
any responsive documents, should they exist, subject to Mobility’s previously stated objections, in
accordance with the schedule established by the Court. However, Motorola is not able to give you a
definitive date for production at this time. Also, as I stated during our call, I believe it would be more
productive for us to meet and confer with respect to those requests to which Mobility has objected. To
this end, I propose that we meet and confer Friday anytime before 2:00 p.m. PST.
Best regards,
Amanda

Amanda Williamson
Quinn Emanuel Urquhart & Sullivan, LLP
500 West Madison Street, Suite 2450
Chicago, IL 60661
312.705.7477 Direct

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From: Eppich, Christopher K [mailto:[e-mail]]
Sent: Friday, September 02, 2011 1:05 PM
To: Amanda Williamson
Cc: Haskett, Christine; Ernst, Samuel
Subject: Apple Inc. et al. v. Motorola, Inc. et al., Case No. 10-cv-662-bbc (W.D. Wis.)

Amanda,

Please find attached correspondence.
Regards,
Chris

Christopher Eppich | COVINGTON & BURLING LLP
Attorney
9191 Towne Centre Drive, 6th Floor
San Diego, CA 92122 | www.cov.com
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