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Case 5:05-cv-00334-RMW Document 2243 Filed 09/22/2008 Page 2 of 3
21 Ex. 4412: Rambus objects to Exhibit 4412 on the ground that the document is
responsive to Rambus’s requests for production in these actions and was
22 not produced by Samsung in discovery in violation of Fed. R. Civ. P. 37(c)
and in violation of Samsung’s disclosure obligations under Fed. R. Civ. P.
23 26(a).
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5976965.1
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Case 5:05-cv-00334-RMW Document 2243 Filed 09/22/2008 Page 3 of 3
1 Exs. 4438 & 4439: Exhibit 4438 is an internal Samsung document in Korean, and Exhibit
4439 is an English translation submitted by Samsung. Rambus objects to
2 these exhibits on ground that they are inadmissible hearsay and contain
within them inadmissible hearsay statements. Fed. R. Evid. 802. Rambus
3 further objects on the ground that the exhibits are responsive to discovery
requests made by Rambus more than two years ago, and yet were not
4 produced until after the close of discovery and less than four weeks before
trial, in violation of Fed. R. Civ. P. 37(c) and Samsung’s disclosure
5 obligations under Fed. R. Civ. P. 26(a). Rambus further objects on the
ground that Mr. Shim is not a proper witness to authenticate these exhibits
6 or otherwise lay the foundation for their admission. Rambus further
objects to the accuracy of the translation and, if these exhibits are admitted
7 into evidence, reserves its right to seek admission of Exhibit No. 10677,
which is a certified English translation of the exhibit that Rambus has
8 obtained from an independent translator.
9 Exs. 4446 & 4446A: Exhibit 4446 is an internal Samsung document in Korean, and Exhibit
4446A is an English translation submitted by Samsung. Rambus objects to
10 these exhibits on ground that they are inadmissible hearsay. Fed. R. Evid.
802. Rambus further objects on the ground that the exhibits are responsive
11 to discovery requests made by Rambus more than two years ago, and yet
were not produced until after the close of discovery and less than three
12 weeks before trial, in violation of Fed. R. Civ. P. 37(c) and Samsung’s
disclosure obligations under Fed. R. Civ. P. 26(a). Rambus further objects
13 on the ground that Mr. Shim is not a proper witness to authenticate these
exhibits or otherwise lay the foundation for their admission. Rambus
14 further objects to the accuracy of the translation and, if these exhibits are
admitted into evidence, reserves its right to seek admission of Exhibit No.
15 10682, which is a certified English translation of the exhibit that Rambus
has obtained from an independent translator.
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Respectfully submitted:
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DATED: September 22, 2008 MUNGER, TOLLES & OLSON LLP
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By: /s/ Keith R. D. Hamilton
21 KEITH R. D. HAMILTON
22 Attorneys for RAMBUS INC.
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