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`IN THE UNITED STATES DISTRICT COURT .
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`CYWEE GROUP LTD.,
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`Plaintiff
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`v.
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`SAMSUNG ELECTRONICS CO. LTD.
`AND SAMSUNG ELECTRONICS
`AMERICA, INC.,
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`Defendants.
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`NO. 2:17-CV-00140-RWS-RSP
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`DECLARATION OF STEVEN M. MOSELEY IN SUPPORT OF DEFENDANTS
`SAMSUNG ELECTRONICS CO., LTD. AND SAMSUNG ELECTRONICS
`AMERICA, INC.'S MOTION TO STRIKE PLAINTIFF CYWEE GROUP LTD.'S
`MOTION TO COMPEL
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`I, Steven M. Moseley, hereby declare as follows:
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`1.
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`I am an attorney at the law firm Paul Hastings LLP, counsel of record for
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`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. in this action. I have
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`personal knowledge of the facts herein and, if called as a witness, I could and would testify
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`competently as to their truth.
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`2.
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`On December 13, Samsung and CyWee met and conferred regarding CyWee's
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`failure to meet and confer with Samsung before filing its motion to compel, as required under
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`Local Rule 7(h), and the excessive length of CyWee's motion to compel in view of the Court's
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`Standing Order. Samsung asked CyWee to provide the legal bases for its arguments, but CyWee
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`refused to do so, maintaining without support that it motion to compel was proper.
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`Ill
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`Ill
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`Ill
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`
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`Case 2:17-cv-00140-RWS-RSP Document 50-1 Filed 12/14/17 Page 2 of 2 PageID #: 1339
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`I declare under penalty of perjury under the laws of the State of California that the
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`foregoing is true and correct. Executed this 14th day of December, 2017 in San Diego,
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`California.
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`Steven P. Mose
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`(I
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`-2-
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`