`
`WASHINGTON, DC
`
`Before The Honorable Theodore R. Essex
`
`In The Matter Of
`
`CERTAIN MOBILE DEVICES AND
`RELATED SOFTWARE
`
`Investigation No. 337—TA-750
`
`UNOPPOSED JOINT MOTION OF COMPLAINANT APPLE,
`
`INC. AND RESPONDENTS MOTOROLA SOLUTIONS, INC. AND
`
`MOTOROLA MOBILITY, INC. FOR LEAVE TO TAKE CERTAIN
`DEPOSITIONS AFTER THE CLOSE OF FACT DISCOVERY
`
`Pursuant to Commission Rules 210.15 and Ground Rule 3, Complainant Apple, Inc.
`
`("Apple") and Respondents Motorola Solutions, Inc. and Motorola Mobility, Inc. ("Motorola")
`
`respectfully move for leave to take six depositions after the close of fact discovery.
`
`The current procedural schedule (Order No. 8) in this investigation establishes July 22,
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`201 1 as the cutoff and completion date for fact discovery. To date, the parties have conducted
`
`31 depositions in this investigation, will take additional depositions this week, and seek leave to
`
`take six fact witness depositions after the July 22, 201 1 close of fact discovery (the hearing in
`
`this Investigation is scheduled for September 26, 2011). Despite diligent efforts by the parties,
`
`scheduling conflicts make it impracticable for the parties to complete six depositions that were
`
`identified and/or noticed within the fact discovery period.
`
`The outstanding fact depositions and their corresponding dates (to the extent known) are
`
`as follows:
`
`
`
`
`
`
`
`
`
`As noted above, with respect to four of the remaining six fact depositions, the parties and
`
`witnesses have tentatively scheduled the deposition dates and times based on witness
`
`availability. With respect to the two unscheduled fact depositions, which were requested by
`
`Motorola during the fact discovery period, Motorola is diligently working to schedule these
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`depositions.
`
`Accordingly, and for good cause shown, Apple and Motorola respectfully request that the
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`presiding Administrative Law Judge issue an order permitting the parties to take the depositions
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`set forth above after the July 22, 2011 close of fact discovery.
`
`Dated: July 22, 2011
`
`Respectfully submitted,
`
`.«.
`
`M
`
`/ /(/l’9!»“"'
`
`avis
`ark G.
`Robert T. Vlasis
`Edward S. Jou
`Weil, Gotshal & Manges LLP
`1300 Eye Street, N.W., Suite 900
`Washington, D.C. 20005
`Tel.: (202) 682-7000
`
`0242651764/4253968.2
`
`2
`
`.M
`
`Charles F. Schill
`Steptoe & Johnson LLP
`1330 Connecticut Avenue, N.W.
`Washington, DC 20036
`Tel.: (202) 429-8162
`
`Charles K. Verhoeven
`David Eiseman
`
`Quinn Emanuel Urquhart & Sullivan LLP
`
`
`
`Matthew D. Powers
`Steven S. Cherensky
`Jason D. Kipnis
`Paul T. Ehrlich
`
`Weil, Gotshal & Manges, LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`Tel.: (650) 802~3000
`
`Attorneys)/i)r (_7()mplaim‘mI Apple Inc.
`
`50 Calilbriiia Street, 22nd Floor
`San Francisco. CA 941 1 1
`'l’e1.: (415) 875-6600
`
`Edward .1. DeFranCo
`Stephen '1“. Straub
`Quinn Emanuel Urquhart & Sullivan LLP
`51 Madison Avenue, 22nd Floor
`New York, NY 10010
`
`Tel; (212) 849~7000
`
`David A. Nelson
`
`Quinn lrlmanuel Urquhart & Sullivan LLP
`500 West Madison Street, Ste. 2450
`Chicago, IL 60661
`Tel: (312) 705—7400
`
`Att()rneysf()r Respondents Motorola
`Solullirms, Inc‘. and Motorola Mobility, Inc.
`
`02426 51764/42539682
`
`D.)
`
`
`
`Cermin Mobile Devices and Related Software
`Investigation N0. .13 7- 724-75!)
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on, July 22, 201 1, she caused the
`Unopposed Joint Motion of Complainant Apple Inc. and Respondents
`Motorola Solutions, Inc. and Mototola Mobility, Inc. for Leave to
`Take Certain Depositions after the Close of Fact Discovery
`to be served on the parties as indicated below:
`
`Via First Class Mail
`
`Secretary
`U.S. International Trade Commission
`
`500 E Street, SW, Room ll2~F
`
`Washington, DC 20436
`
`The Honorable Theodore R. Essex
`
`Administrative Law Judge
`U.S. International Trade Commission
`
`500 E Street, SW, Room 317
`
`Washington, l)C 20436
`
`Lisa Kattan
`
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`
`500 E Street, SW
`
`Washington, DC 20436
`
`Mark Davis, Esq.
`Weil, Gotshall & Manges LLP
`1300 Eye Street, NW, Suite 900
`Washington, DC 20005
`
`Counsel for (lamp/aimmt, Apple Inc.
`
`Via Hand Delivery
`(()/dginczlplus six)
`Via Electronic Filing (EDIS)
`Via Overnight Courier
`Via Facsimile
`
`Via l3—mail (PDF)
`
`Via First Class Mail
`
`Via Hand Delivery
`Two (j‘0pie.s'
`Via Overnight Courier
`Via Facsimile
`
`Via E—mail (PDF)
`
`EDDDDEDDamDUDEDD Via First Class Mail
`
`Via Hand Delivery
`Via Overnight Courier
`Via Facsimile
`
`Via Email (PDF)
`/L1/<.éi££§!f;£;£?;:L4§IL£é;£!tQE
`
`EDDEU Via First Class Mail
`
`Via Hand Delivery
`Via Overnight Courier
`Via Facsimile
`
`Via E—mail (PDF)
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`
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`
`iii‘Timali<a R. pn
`Paralegal Specialist
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