Unites States of America v. Apple, Inc. et al

Filing 426

DECLARATION of CYNTHIA E. RICHMAN in Support re: 425 Letter. Document filed by Apple, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F)(Boutrous, Theodore)

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------------x : UNITED STATES OF AMERICA, : : Plaintiff, : : v. : : APPLE INC., et al., : : Defendants. : : -------------------------------------x -------------------------------------x : THE STATE OF TEXAS, : THE STATE OF CONNECTICUT, et al., : : Plaintiffs, : : v. : : PENGUIN GROUP (USA) INC., et al., : : Defendants. : : -------------------------------------X 12 Civ. 2826 (DLC) 12 Civ. 03394 (DLC) DECLARATION OF CYNTHIA E. RICHMAN I, CYNTHIA E. RICHMAN, pursuant to 28 U.S.C. § 1746, declare: 1. I am an attorney duly licensed to practice law in the District of Columbia and State of Maryland. I have been given permission to appear before the United States District Court for the Southern District of New York pro hac vice. I am a partner at Gibson, Dunn & Crutcher LLP and am one of the attorneys representing Apple Inc. in the above-captioned matter. I respectfully submit this declaration in support of Apple’s January 7, 2014 letter to the Court regarding its objections to the External Compliance Monitor. I have personal knowledge of the matters stated herein and, if called upon to do so, could and would competently testify thereto. 2. Attached hereto as Exhibit A is a true and correct copy of a letter from Theodore J. Boutrous, Jr. to J. Robert Kramer, II and Gabriel Gervey, sent on October 31, 2013. 3. Attached hereto as Exhibit B is a true and correct copy of a letter from Theodore J. Boutrous, Jr. to Lawrence E. Buterman and Gabriel Gervey, sent on November 27, 2013. 4. Attached hereto as Exhibit C is a true and correct copy of a letter from Theodore J. Boutrous, Jr. to Lawrence E. Buterman and Gabriel Gervey, sent on December 6, 2013. 5. Attached hereto as Exhibit D is a true and correct copy of a letter from Noreen Krall to Lawrence E. Buterman and Eric Lipman, sent on December 17, 2013. 6. Attached hereto as Exhibit E is a true and correct copy of a letter from Theodore J. Boutrous, Jr. to Lawrence E. Buterman and Gabriel Gervey, sent on December 21, 2013. 7. Attached hereto as Exhibit F is a true and correct copy of a letter from Theodore J. Boutrous, Jr. to Lawrence E. Buterman and Gabriel Gervey, sent on January 3, 2014. 2 I declare under penalty of perjury, under the laws of the United States, that the foregoing is true and correct. Dated: January 7, 2014 Respectfully submitted, ynthia E. Richman