In filing #2012 Samsung says this: 3. In response to Samsung’s motion detailing Velvin Hogan’s failure to reveal his litigation with Seagate during voir dir

In filing #2012 Samsung says this: 3. In response to Samsung’s motion detailing Velvin Hogan’s failure to reveal his litigation with Seagate during voir dire and its impact on the integrity of the trial and the verdict, Apple demanded that Samsung disclose the timing of its knowledge regarding those facts. A true and correct copy of Apple’s email, along with further correspondence between counsel for the parties that resulted in Apple’s agreement that any such disclosures would not constitute a waiver of any privilege, is attached hereto as Exhibit A. By way of separate declaration, Samsung is confirming to Apple that it did not know of Mr. Hogan’s undisclosed litigation against Seagate until after the verdict. To date, Apple has not revealed whether it was aware of Mr. Hogan’s litigation against Seagate prior to the verdict or prior to Samsung’s Motion.