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JONATHAN M. REDGRAVE 

jredgrave@redgravellp.com (PHV submitted) 

CHARLES R. RAGAN (SBN: 072319) 

cragan@redgravellp.com 

SCOTT J. BORROWMAN (SBN: 241021) 

sborrowman@redgravellp.com 

REDGRAVE LLP 

455 Market Street, Suite 1920 

San Francisco, CA 94105 

Telephone: (415) 471-2046 

Facsimile: 

ALYSSA CARIDIS (SBN: 260103) 

acaridis@orrick.com 

WENDY BUTLER CURTIS 

wcurtis@orrick.com (PHV submitted) 

ORRICK, HERRINGTON & SUTCLIFFE LLP 

The Orrick Building 

405 Howard Street 

San Francisco, CA 94105-2669 

Telephone: (415) 773-5700 

Facsimile: 

Attorneys for Amicus Curiae 

LAWYERS FOR CIVIL JUSTICE 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN JOSE DIVISION 

FEDERAL TRADE COMMISSION, et al. 

 Plaintiffs, 

 v. 

QUALCOMM INCORPORATED, et al., 

 Defendants. 

In re Qualcomm Antitrust Litigation 

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Case No.: 5:17-cv-00220-LHK 

Case No.: 5:17-md-02773-LHK 

ADMINISTRATIVE MOTION OF 

LAWYERS FOR CIVIL JUSTICE TO 

FILE BRIEF AS AMICUS CURIAE

(LOCAL RULE 7-11) 

Hearing Date: February 15, 2018 

Hearing Time: 1:30 PM 

Courtroom: 8, 4th Floor 

THE HONORABLE LUCY H. KOH 
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I. INTRODUCTION 

Lawyers for Civil Justice (“LCJ”) respectfully moves for leave to file an amicus curiae

brief in support of Non-Party Apple Inc.’s Motion for Relief from Magistrate Judge’s 

Nondispositive Pretrial Order Imposing Sanctions. A copy of the proposed brief is attached as 

Exhibit A to this motion. Apple consents to the filing of this motion and the accompanying 

amicus brief. Qualcomm does not consent to filing. 

II. IDENTITY AND INTEREST OF AMICUS CURIAE 

LCJ is a national coalition of corporations, defense bar organizations, and law firms that 

promotes excellence and fairness in the civil justice system to secure the just, speedy, and 

inexpensive determination of civil cases. For over 25 years, LCJ has been closely engaged in 

reforming federal civil rules to: (1) promote balance in the civil justice system; (2) reduce costs 

and burdens associated with litigation; and (3) advance predictability and efficiency in litigation. 

LCJ has a unique perspective on the rules amendments, having been directly involved in the 

entire process related to the adoption of the 2015 rules amendments, including participating in 

the 2010 Duke Conference, submitting empirical evidence in support of changes to the discovery 

rules and other materials such as White Papers, and participating in all the hearings and Rules 

Advisory Committee meetings. 

III. REASONS WHY THE MOTION SHOULD BE GRANTED 

The District Courts have “broad discretion” to accept an amicus curiae submission. 

Hoptowit v. Ray, 682 F. 2d 1237, 1260 (9th Cir. 1982). “District courts frequently welcome 

amicus briefs from non-parties concerning legal issues that have potential ramifications beyond 

the parties directly involved or if the amicus has ‘unique information or perspective that can help 

the court beyond the help that the lawyers for the parties are able to provide.’” NGV Gaming, 

Ltd. V. Upstream Point Molate, LLC, 355 F. Supp. 2d 1061, 1067 (N.D. Cal. 2005) (quoting 

Cobell v. Norton, 246 F. Supp. 2d 59, 62 (D.D.C.2003)). If permitted to file, LCJ will fulfill “the 

classic role of amicus curiae by assisting in a case of general public interest[] [and]