`Subject: RE: IPR2018-00884: Dr. Easttom Deposition
`Date: March 28, 2019 at 3:14 PM
`To: Adam Seitz adam.seitz@eriseip.com
`Cc: Ryan Loveless ryan@etheridgelaw.com, Paul Hart paul.hart@eriseip.com, Danny Butts danny@etheridgelaw.com, Jeff Huang
`jeff@etheridgelaw.com, Jim Etheridge jim@etheridgelaw.com, Travis Richins travis@etheridgelaw.com
`
`IPR2018-00884
`Apple Inc. EX1024 Page 1
`
`
`
`Adam,
`
`Mr. Eas,om is not available next week or the week a9er for deposi<on and, therefore, our
`concerns about a compressed schedule remain valid. We repeat our observa<on that this
`possibly could have been avoided had Pe<<oner not taken nearly two weeks to update us on its
`posi<on.
`
`You are welcome to send the Board a non-argumenta<ve email, though we request that you copy
`us first on a dra9 of the email so that we may comment and make certain it accurately conveys
`the facts.
`
`Regards,
`Bre,
`
`From: Adam Seitz <adam.seitz@eriseip.com>
`Sent: Thursday, March 28, 2019 3:53 PM
`To: Bre, Mangrum <bre,@etheridgelaw.com>
`Cc: Ryan Loveless <ryan@etheridgelaw.com>; Paul Hart <paul.hart@eriseip.com>; Danny Bu,s
`<danny@etheridgelaw.com>; Jeff Huang <jeff@etheridgelaw.com>; Jim Etheridge
`<jim@etheridgelaw.com>; Travis Richins <travis@etheridgelaw.com>
`Subject: Re: IPR2018-00884: Dr. Eas,om Deposi<on
`
`Bre,,
`
`Our response is actually due April 16. That date was modified as part of your request to extend
`the Patent Owner Response deadline. (See the a,ached.) Given the actual deadline, we do not
`share your concerns about a “compressed schedule.”
`
`Your email about producing Dr. Eas,om tomorrow was the first <me you indicated you would
`produce him and gave us less than 4 hours in the business day to make arrangements to travel for
`a deposi<on at an unknown loca<on. That is unreasonable and unfair and we will not be
`proceeding with his deposi<on tomorrow.
`
`We look forward to hearing when Dr. Eas,om is available next week. If you are refusing to
`produce him next week, then I suggest we send an email to the Board and address this with
`them.
`
`Thanks,
`
`Adam
`
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`confidential communication to the intended recipient, you have received this communication in error, and any review, use, dissemination, forwarding, printing, copying,
`or other distribution of this email message and any attached files is strictly prohibited. Erise IP, P.A. reserves the right to monitor any communication that is created,
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`
`IPR2018-00884
`Apple Inc. EX1024 Page 2
`
`
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