"The Apple iPod iTunes Anti-Trust Litigation"

Filing 767

Administrative Motion to File Under Seal Portions of Plaintiffs Reply Memorandum in Support of Motion to Strike the Supplemental Report of Kevin M. Murphy and Robert H. Topel, dated December 20, 2013 filed by Somtai Troy Charoensak, Mariana Rosen, Melanie Tucker. (Attachments: # 1 Declaration of Bonny E. Sweeney in Support of Motion to Seal, # 2 Proposed Order Granting Motion to Seal, # 3 Redacted Version of Reply Memorandum in Support of Plaintiffs' Motion to Strike the Supplemental Report of Murphy and Topel, dated December 20, 2013, # 4 Unredacted Version of Reply Memorandum in Support of Plaintiffs' Motion to Strike the Supplemental Report of Murphy and Topel, dated December 20, 2013)(Sweeney, Bonny) (Filed on 2/3/2014)

1 ROBBINS GELLER RUDMAN
& DOWD LLP
2 BONNY E. SWEENEY (176174)
THOMAS R. MERRICK (177987)
3 ALEXANDRA S. BERNAY (211068)
CARMEN A. MEDICI (248417)
4 JENNIFER N. CARINGAL (286197)
655 West Broadway, Suite 1900
5 San Diego, CA 92101
Telephone: [phone]
6 619/231-7423 (fax)
[e-mail]
7 [e-mail]
[e-mail]
8 [e-mail]
[e-mail]
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Class Counsel for Plaintiffs
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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OAKLAND DIVISION
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THE APPLE IPOD ITUNES ANTI-TRUST
15 LITIGATION
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This Document Relates To:
ALL ACTIONS.

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Lead Case No. C-05-00037-YGR
CLASS ACTION
DECLARATION OF BONNY E. SWEENEY
IN SUPPORT OF PLAINTIFFS’
ADMINISTRATIVE MOTION TO FILE
PORTIONS OF PLAINTIFFS’ REPLY
MEMORANDUM IN SUPPORT OF
MOTION TO STRIKE THE
SUPPLEMENTAL REPORT OF KEVIN M.
MURPHY AND ROBERT H. TOPEL,
DATED DECEMBER 20, 2013 UNDER
SEAL PURSUANT TO CIVIL L.R. 7-11
AND 79-5

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DATE:
TIME:
CTRM:
JUDGE:

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911786_1

TBD
TBD
5, 2nd Floor
Hon. Yvonne Gonzalez Rogers

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I, Bonny E. Sweeney, declare:

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1.

I am an attorney duly licensed to practice before all of the courts of the State of

3 California. I am a member of the law firm of Robbins Geller Rudman & Dowd LLP, Class Counsel
4 for the Class and for Plaintiffs Melanie Tucker, Mariana Rosen and Somtai Troy Charoensak
5 (collectively, “plaintiffs”) in this action. I have personal knowledge of the matters stated herein, and,
6 if called upon, I could and would competently testify thereto.
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2.

I submit this declaration in support of Plaintiffs’ Administrative Motion to File Under

8 Seal Portions of Plaintiffs’ Reply Memorandum in Support of Motion to Strike the Supplemental
9 Report of Kevin M. Murphy and Robert H. Topel, dated December 20, 2013 (“Reply”). The
10 document at issue includes material that has been designated confidential under the Stipulated
11 Protective Order Regarding Confidential Information (“Protective Order”).

It is plaintiffs’

12 understanding that Apple wishes the documents to remain confidential.
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3.

Such filing under seal is necessitated by the designation of certain documents that are

14 quoted, paraphrased and referenced in the Reply as “Confidential” by Apple.
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4.

Under the terms of the existing Protective Order, plaintiffs are obligated to file the

16 Reply, which reference documents designated as “Confidential,” under seal.
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I declare under penalty of perjury under the laws of the United States of America that the

18 foregoing is true and correct. Executed this 3rd day of February, 2014, at San Diego, California.
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s/ Bonny E. Sweeney
BONNY E. SWEENEY

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911786_1

DEC OF BES ISO PLTFS’ ADMIN MOT TO FILE PORTIONS OF PLTFS’ REPLY MEMO ISO MTS
THE SUPP RPT OF MURPHY & TOPEL, DATED DECEMBER 20, 2013 - C-05-00037-YGR

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CERTIFICATE OF SERVICE
I hereby certify that on February 3, 2014, I authorized the electronic filing of the foregoing

3 with the Clerk of the Court using the CM/ECF system which will send notification of such filing to
4 the e-mail addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I
5 caused to be mailed the foregoing document or paper via the United States Postal Service to the non6 CM/ECF participants indicated on the attached Manual Notice List.
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I certify under penalty of perjury under the laws of the United States of America that the

8 foregoing is true and correct. Executed on February 3, 2014.
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s/ Bonny E. Sweeney
BONNY E. SWEENEY

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ROBBINS GELLER RUDMAN
& DOWD LLP
655 West Broadway, Suite 1900
San Diego, CA 92101-3301
Telephone: [phone]
619/231-7423 (fax)

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E-mail:

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[e-mail]

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Mailing Information for a Case 4:05-cv-00037-YGR "The Apple
iPod iTunes Anti-Trust Litigation"
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Amir Q Amiri
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Francis Joseph Balint , Jr
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Michael D. Braun
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Caroline Nason Mitchell
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Robert Allan Mittelstaedt
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Brian P. Murray
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George A. Riley
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Elaine A. Ryan
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Jacqueline Sailer
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Michael Tedder Scott
[e-mail]
Craig Ellsworth Stewart
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Bonny E. Sweeney
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Helen I. Zeldes
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