`
`1001 Pennsylvania Avenue, N.W., Washington, DC 20004-2595 g p202 624-2500 g f202 628-5116
`
`
`
`Astor Henry Lloyd Heaven
`(202) 624-2599
`aheaven@crowell.com
`
`
`
`
`
`March 13, 2018
`
`
`
`VIA ECF
`
`Magistrate Judge Donna M. Ryu
`United States District Court for the Northern District of California
`
`Oakland Courthouse, Courtroom 4 - 3rd Floor
`1301 Clay Street, Oakland, CA 94612
`
`
`Re:
`
` Ward v. Apple Inc., No. 4:12-cv-05404
`
`Dear Judge Ryu:
`
`We write to supplement the Joint Discovery Letter (Dkt. 205) filed by Plaintiffs in Ward
`v. Apple Inc., No. 4:12-cv-05404, and third parties AT&T Mobility LLC (“ATTM”), Glenn
`Lurie, and Ralph De La Vega.
`
`On March 8, 2018, Plaintiffs served a document subpoena (the “March 8 Subpoena”) on
`ATTM that included 9 additional requests for production. ATTM served objections to the
`document subpoena on March 12, 2018. Because ATTM had yet to serve objections to the
`March 8 Subpoena at the time the parties filed the Joint Discovery Letter, ATTM only requested
`that the Court quash the first five subpoenas served on ATTM, its employees, and former
`officers, and not the March 8 Subpoena.
`
`The parties now dispute ATTM’s discovery obligations in response to the March 8
`Subpoena, given the current status of the case. Plaintiffs argue that they need the requested
`discovery from ATTM given ATTM’s role in the provision of iPhone voice and data service, and
`ATTM argues that the additional requests (which, together with the previous document
`subpoena, now total 89 pending requests) are not proportional to the needs of the case. The
`parties’ current positions mirror the positions articulated in the Joint Discovery Letter. Because
`any ruling on the Joint Discovery Letter would likely pertain to all of the subpoenas, the parties
`respectfully request that Your Honor also include the March 8 Subpoena in its assessment of the
`parties’ discovery dispute.
`
`
`
`
`
`
`
`Crowell & Moring LLP g www.crowell.com g Washington, DC g New York g San Francisco g Los Angeles g Orange County g London g Brussels
`
`
`
`
`
`
`
`
`
`Case 4:12-cv-05404-YGR Document 207 Filed 03/13/18 Page 2 of 2
`
`Magistrate Judge Donna M. Ryu
`March 13, 2018
`Page 2
`
`Very truly yours,
`
`
`
`/s/_____________
`
`
`Katie Yablonka
`Astor H.L. Heaven (pro hac vice)
`
`
`
`cc: Mark C. Rifkin (by email)
`
`Michael Liskow (by email)
`
`
`
`
`
`
`
`
`
`
`
`/s/___________________
`Rachele R. Rickert
`
`
`
`
`
`
` Crowell & Moring LLP g www.crowell.com g Washington, DC g New York g San Francisco g Los Angeles g Orange County g London g Brussels
`
`
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