EXHIBIT 3 

Case 2:23-cv-00285-JRG-RSP Document 43-4 Filed 02/22/24 Page 1 of 5 PageID #: 447
From: Jordan Flournoy [LEGAL] j.flournoy@sea.samsung.com

Subject: RE: Cobblestone Subpoenas to SEA (EDTX: 2:22-cv-00477)

Date: September 1, 2023 at 2:27AM

To: Matthew Aichele maichele@raklaw.com

Cc: rak_cobblestone@raklaw.com

Caution: This email originated outside of the organization. Do not click links or open

any attachments unless you recognize the sender and know the content is safe. 

Hi Matthew,

Thanks for the call earlier today. As discussed, attached are SEA’s responses and

objections to the subpoenas. I’m happy to jump on a call to meet and confer. Next week

I’m in depos all week, but I anticipate that my depos on Tuesday and Wednesday should be

done by 3 CST. So if you want to try to talk after 3 pm CST on either day, let me know and

we can set something up.

Best regards,

Jordan

Jordan Flournoy

Senior Director, Litigation

Legal – Litigation/Risk Management

Samsung Electronics America, Inc.

M. +1.972.206.7507

j.flournoy@sea.samsung.com

www.samsung.com/us

From: Matthew Aichele [mailto:maichele@raklaw.com]

Sent: Thursday, August 31, 2023 10:09 AM

To: Jordan Flournoy [LEGAL] <j.flournoy@sea.samsung.com>

Cc: rak_cobblestone@raklaw.com

Subject: Re: Cobblestone Subpoenas to SEA (EDTX: 2:22-cv-00477)

Hi Jordan,

I write to follow up on Cobblestone’s subpoena to SEA. Specifically, did SEA provide its

responses and objections as indicated below? If so, could you please re-send? Apologies if I

missed it. If not, please let me know when you are available next week to further meet and

confer on the document subpoena. 

Regards,

Matthew

Matthew D. Aichele | Russ August & Kabat

800 Maine Avenue SW, Suite 200 | Washington, DC 20024

(202) 664-0623 | maichele@raklaw.com | www.raklaw.com

On Aug 2, 2023, at 7:27 PM, Jordan Flournoy [LEGAL]

Case 2:23-cv-00285-JRG-RSP Document 43-4 Filed 02/22/24 Page 2 of 5 PageID #: 448
Caution: This email originated outside of the organization. Do not click

links or open any attachments unless you recognize the sender and know

the content is safe. 

On Aug 2, 2023, at 7:27 PM, Jordan Flournoy [LEGAL]

<j.flournoy@sea.samsung.com> wrote:

Hi Matthew,

Thanks for getting back to me. Thank you for the courtesy extension as to 1)

and 2) below. With respect to a deposition, SEA agrees that we can discuss

whether a deposition is necessary—and if necessary, the timing and scope of

the deposition—after we serve our document production. But our agreements

as to items 1-3 would, of course, be subject to and without waiving Samsung’s

responses and objections to the subpoenas, which we will serve on or before

8/17/23.

Best regards,

Jordan

Jordan Flournoy

Senior Director, Litigation

Legal – Litigation/Risk Management

Samsung Electronics America, Inc.

M. +1.972.206.7507

j.flournoy@sea.samsung.com

www.samsung.com/us

From: Matthew Aichele [mailto:maichele@raklaw.com]

Sent: Wednesday, August 2, 2023 2:59 PM

To: Jordan Flournoy [LEGAL] <j.flournoy@sea.samsung.com>

Cc: rak_cobblestone@raklaw.com

Subject: Re: Cobblestone Subpoenas to SEA (EDTX: 2:22-cv-00477)

Hi Jordan,

Thank you for reaching out. We agree to the extensions outlined as 1) and 2)

below. As for the third, we agree to forgo the noticed deposition date of August

18, provided that SEA agrees the deposition will be rescheduled once Samsung

has provided the document discovery requested.

Regards,

Matthew

Matthew D. Aichele | Russ August & Kabat

800 Maine Avenue SW, Suite 200 | Washington, DC 20024

(202) 664-0623 | maichele@raklaw.com | www.raklaw.com

Case 2:23-cv-00285-JRG-RSP Document 43-4 Filed 02/22/24 Page 3 of 5 PageID #: 449
On Aug 1, 2023, at 6:38 PM, Jon Ma <jma@raklaw.com> wrote:

+Cobblestone Team

Hi Jordan,

We will consider your request and promptly get back to you.

Best,

Jon

Jon Ma

Russ August & Kabat

12424 Wilshire Boulevard, 12th Floor | Los Angeles, California

90025

Main +1 310 826 7474 | jma@raklaw.com

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

This communication shall not create, waive or modify any right,

obligation or liability, or be construed to contain or be an electronic

signature. This communication may contain information that is

legally privileged, confidential or exempt from disclosure, and is

intended only for the named addressee(s). If you are not the

intended recipient, please note that any dissemination, distribution,

or copying of this communication is prohibited.

On Aug 1, 2023, at 3:26 PM, Jordan Flournoy [LEGAL]

<j.flournoy@sea.samsung.com> wrote:

Dear Jonathan,

Samsung Electronics America, Inc. (SEA) is in receipt of

deposition and document subpoenas from your client,

Cobblestone Wireless, in relation to EDTX Case No. 2:22-cv00477.

I write to request i) a courtesy extension of 14 days until 8/17/23 to

respond to the subpoenas, 2) a courtesy 30-day extension for any

document production in response to the document subpoena until

9/13/23, and 3) no deadline for a deposition—if a depo is needed,

it can be scheduled in relation to any document production.

Please confirm whether you are amenable to these extensions.

Best regards,

Jordan

Jordan Flournoy

Senior Director, Litigation

Case 2:23-cv-00285-JRG-RSP Document 43-4 Filed 02/22/24 Page 4 of 5 PageID #: 450
Senior Director, Litigation

Legal – Litigation/Risk Management

Samsung Electronics America, Inc.

M. +1.972.206.7507

j.flournoy@sea.samsung.com

www.samsung.com/us

This email has been scanned for spam and viruses by Proofpoint Essentials. Click here to report

this email as spam.

Samsung Electronics America

Responses and Objections to...

Cobblestone Subpoenas.pdf 566 KB

Case 2:23-cv-00285-JRG-RSP Document 43-4 Filed 02/22/24 Page 5 of 5 PageID #: 451