In re: High-Tech Employee Antitrust Litigation

Filing 319

Administrative Motion to File Under Seal re Google's Opposition to Plaintiffs' Motion to Compel and Supporting Documents filed by Google Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Declaration of Laszlo Bock, #4 Declaration of Eric B. Evans, #5 Proposed Order)(Evans, Eric) (Filed on 1/25/2013)

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1 2 3 4 5 6 7 8 9 MAYER BROWN LLP LEE H. RUBIN (SBN 141331) EDWARD D. JOHNSON (SBN 189475) DONALD M. FALK (SBN 150256) ERIC B. EVANS (SBN 232476) Two Palo Alto Square, Suite 300 3000 El Camino Real Palo Alto, CA 94306-2112 Telephone: (650) 331-2000 Facsimile: (650) 331-2061 Attorneys for Defendant Google Inc. 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN JOSE DIVISION 13 14 IN RE: HIGH-TECH EMPLOYEE ANTITRUST LITIGATION 15 THIS DOCUMENT RELATES TO: 16 Master Docket No. 11-CV-2509-LHK ALL ACTIONS DECLARATION OF ERIC B. EVANS IN SUPPORT OF ADMINISTRATIVE MOTION TO SEAL PORTIONS OF DEFENDANT GOOGLE’S OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL GOOGLE DOCUMENTS AND THE DECLARATION OF WILLIAM CAMPBELL IN SUPPORT THEREOF 17 18 19 20 21 22 I, Eric B. Evans, declare as follows: 23 1. I am a partner with the law firm of Mayer Brown LLP, counsel for Defendant 24 Google, Inc. (“Google”) in the above-captioned matter. I am admitted to practice law before 25 this Court. I submit this declaration in support of Google’s Administrative Motion to Seal 26 Portions of Google’s Opposition to Plaintiffs’ Motion to Compel Google Documents and the 27 Declaration of William Campbell in Support Thereof that is being filed concurrently herewith. 28 1 DECL. OF ERIC B. EVANS ISO GOOGLE’S ADMIN. MOTION TO SEAL MASTER DOCKET NO. 11-CV-2509-LHK 1 As an attorney involved in the defense of this action, unless otherwise stated, I have personal 2 knowledge of the facts stated in this declaration and if called as a witness, I could and would 3 competently testify to them. 4 2. I have read and reviewed the Declaration of Laszlo Bock also filed concurrently 5 herewith, which describes the competitive harm that Google would suffer if information in the 6 Declaration of William Campbell were made public. Specifically, Mr. Bock testified that were 7 this information made public Google’s competitors would discover and therefore better 8 understand, the unique and confidential arrangement between Mr. Campbell and Google 9 regarding his role as senior advisor to Google, including how this arrangement was formalized 10 and documented and the details and express terms and conditions of that arrangement (such as 11 the specific manner in which Mr. Campbell has been, and continues to be, compensated for his 12 work as a senior advisor to Google). 13 3. I have also read and reviewed Google’s Opposition to Plaintiffs’ Motion to 14 Compel. The proposed redactions to the Opposition contain or quote information from the 15 Declaration of William Campbell. 16 4. Accordingly, and for the reasons articulated in the Declaration of Lazlo Bock, 17 these excerpts contain highly confidential information, and Google would suffer competitive 18 harm if such excerpts were made public. 19 20 5. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on January 25, 2013 in Palo Alto, California. 21 22 _s/ Eric B. Evans___________________ Eric B. Evans 23 24 25 26 27 28 -2- DECL. OF ERIC B. EVANS ISO GOOGLE’S ADMIN. MOTION TO SEAL MASTER DOCKET NO. 11-CV-2509-LHK

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