`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`JAWBONE INNOVATIONS, LLC,
`
`
`
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD., ET AL.
`
`Defendants.
`
`
`
`
`
`
`NO. 2:21-CV-0186-JRG-RSP
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`
`
`
`UNOPPOSED MOTION TO EXCUSE LEAD COUNSEL FROM
`DISCOVERY MEET AND CONFER AND MOTIONS HEARING
`
`On Wednesday September 7, 2022, the Court ordered a hearing for Monday, September
`
`26, 2022, on the following discovery motions: [170] Opposed Sealed Motion to Compel
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`Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. to Provide
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`Supplemental Interrogatory Responses; [169] Opposed Sealed Motion to Compel Defendants
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`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. to Provide QACT; [121]
`
`Motion to Compel; [171] Opposed Sealed Motion to Compel Defendants Samsung Electronics
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`Co., Ltd. and Samsung Electronics America, Inc. to Provide Rule 30(b)(6) Testimony; [139]
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`Opposed Sealed Motion to Compel Defendants Samsung Electronics Co., Ltd. and Samsung
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`Electronics America, Inc. to Provide Information Relative to Qualcomm; [130] Sealed Patent
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`Motion to Compel; and [172] Opposed Sealed Motion to Compel.
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`Before that order, Jin-Suk Park, lead counsel for Defendants, had already made
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`arrangements to be in Korea for discovery in another case. Accordingly, he is unable to attend
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`the September 26, 2022 hearing because he will be out of the country in Korea and is not
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`scheduled to return to United States until October 1. Additionally, Mr. Park will be in transit to
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`1
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`Case 2:21-cv-00186-JRG-RSP Document 188 Filed 09/08/22 Page 2 of 4 PageID #: 9950
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`Korea on Monday, September 12, 2022, when the parties are currently looking to set a meet and
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`confer regarding the discovery motions.
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`Chief Judge Gilstrap’s Standing Order Regarding “Meet and Confer” Obligations
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`Relating to Discovery Disputes dated March 11, 2020 requires that “each party’s lead attorney
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`shall attend any discovery motion hearing set by the Court.” The Standing Order further requires
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`that “each party’s lead attorneys . . . and local counsel shall meet and confer” in an effort to
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`resolve the discovery disputes prior to the discovery hearing.
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`Defendants respectfully request that the Court excuse Mr. Park’s presence from the
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`discovery hearing and meet and confer and request that Ryan M. Nishimoto be allowed to act as
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`lead counsel with decision making authority at the hearing and meet and confer in place of lead
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`counsel. Counsel for the Plaintiff does not oppose these requests.
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` Accordingly, Defendants move the Court to enter the attached order excusing Mr. Park
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`from the September 26, 2022 discovery hearing and the September 12, 2022 discovery meet and
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`confer.
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`2
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`Case 2:21-cv-00186-JRG-RSP Document 188 Filed 09/08/22 Page 3 of 4 PageID #: 9951
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`Dated: September 8, 2022
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`Respectfully submitted,
`
`/s/ Melissa Smith
`Melissa Smith
`melissa@gillamsmithlaw.com
`GILLAM & SMITH LLP
`303 South Washington Avenue
`Marshall, TX 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`
`Jin-Suk Park
`jin.park@arnoldporter.com
`Paul Margulies
`paul.margulies@arnoldporter.com
`ARNOLD & PORTER KAYE SCHOLER
`LLP
`601 Massachusetts Ave., NW
`Washington, DC 20001-3743
`Telephone: (202) 942-5000
`Facsimile: (202) 942-5555
`
`Patrick C. Reidy
`patrick.reidy@arnoldporter.com
`ARNOLD & PORTER KAYE SCHOLER
`LLP
`70 West Madison Street, Suite 4200
`Chicago, IL 60602
`Telephone: (312) 583-2424
`Facsimile: (312) 583-2360
`
`Ryan M. Nishimoto
`ryan.nishimoto@arnoldporter.com
`Daniel S. Shimell
`daniel.shimell@arnoldporter.com
`ARNOLD & PORTER KAYE SCHOLER
`LLP
`777 South Figueroa Street, 44th Floor
`Los Angeles, CA 90017
`Telephone: (213) 243-4000
`Facsimile: (213) 243-4199
`
`Attorneys for Samsung Electronics Co., Ltd. and
`Samsung Electronics America, Inc.
`
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`3
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`Case 2:21-cv-00186-JRG-RSP Document 188 Filed 09/08/22 Page 4 of 4 PageID #: 9952
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`
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`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing documents was filed electronically in
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`compliance with Local Rule CV-5(a). As such, this document was served on all counsel who has
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`consented to electronic service, on this 8th day of September 2022.
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`/s/ Melissa R. Smith
`Melissa R. Smith
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that Counsel for Plaintiff and Counsel for Defendants have complied
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`with the meet and confer requirement in Local Rule CV-7(h) regarding this Motion by
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`conferring via e-mail on September 8, 2022. Counsel for Plaintiff indicated Plaintiff is
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`unopposed to the relief sought herein.
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`/s/ Melissa R. Smith
` Melissa R. Smith
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`4
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