In re: High-Tech Employee Antitrust Litigation

Filing 318

OPPOSITION to ( #278 MOTION to Compel Google Documents [REDACTED] ) filed byGoogle Inc.. (Attachments: #1 Declaration of Lee H. Rubin, #2 Declaration of Alan Eustace)(Evans, Eric) (Filed on 1/25/2013) Modified text on 1/28/2013 (dhmS, COURT STAFF).

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MAYER BROWN LLP
LEE H. RUBIN (SBN 141331)
[e-mail]
EDWARD D. JOHNSON (SBN 189475)
[e-mail]
DONALD M. FALK (SBN 150256)
[e-mail]
ERIC B. EVANS (SBN 232476)
[e-mail]
Two Palo Alto Square, Suite 300
3000 El Camino Real
Palo Alto, CA 94306-2112
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendant
Google Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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IN RE: HIGH-TECH EMPLOYEE
ANTITRUST LITIGATION
THIS DOCUMENT RELATES TO:
ALL ACTIONS

Master Docket No. 11-CV-2509-LHK
DECLARATION OF LEE H. RUBIN IN
SUPPORT OF GOOGLE INC.’S
OPPOSITION TO PLAINTIFFS’
MOTION TO COMPEL PRODUCTION
OF DOCUMENTS
Date:
Time:
Courtroom:
Judge:

February 26, 2013
10:00 a.m.
5, 4th Floor
Honorable Paul S. Grewal

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RUBIN DECL. IN SUPPORT OF GOOGLE’S OPPOSITION TO MOTION TO COMPEL
MASTER DOCKET NO. 11-CV-2509-LHK

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I, Lee H. Rubin, declare:

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1.

I am a member of the Bar of the State of California and a partner of the law firm of

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Mayer Brown LLP, attorneys for Defendant Google Inc. I submit this declaration in support of

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Google’s Opposition to Compel Production of Documents. I make this declaration based on my

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own personal knowledge. If called to testify as a witness, I could and would do so competently.

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2.

On the morning of January 25, 2013, I placed a call to Dean Harvey at Lieff,

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Cabraser, Heimann and Bernstein, attorneys for Plaintiffs in this action. On the call, I offered to

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share with Plaintiffs’ counsel the declaration that Google intended to file in support of Google’s

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Opposition to Plaintiffs’ Motion To Compel Production of Documents. I further proposed that the

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parties stipulate to a one-day extension of time for Google to file its opposition brief to allow time

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for Google to share the declaration and to have an opportunity to meet and confer in advance of

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Google’s current filing deadline.

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3.

In the late afternoon of January 25, 2013, Dean Harvey notified my partner, Eric

Evans, that Plaintiffs declined Google’s proposal.

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Executed on January 25, 2012, in Palo Alto, California.

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By: /s/ Lee H. Rubin______________________________
Lee H. Rubin

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RUBIN DECL. IN SUPPORT OF GOOGLE’S OPPOSITION TO MOTION TO COMPEL
MASTER DOCKET NO. 11-CV-2509-LHK