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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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]
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

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THIS DOCUMENT RELATES TO:

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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

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I, Eric B. Evans, declare as follows:

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1.

I am a partner with the law firm of Mayer Brown LLP, counsel for Defendant

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Google, Inc. (“Google”) in the above-captioned matter. I am admitted to practice law before

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this Court. I submit this declaration in support of Google’s Administrative Motion to Seal

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Portions of Google’s Opposition to Plaintiffs’ Motion to Compel Google Documents and the

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Declaration of William Campbell in Support Thereof that is being filed concurrently herewith.

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DECL. OF ERIC B. EVANS ISO GOOGLE’S ADMIN. MOTION TO SEAL
MASTER DOCKET NO. 11-CV-2509-LHK

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As an attorney involved in the defense of this action, unless otherwise stated, I have personal

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knowledge of the facts stated in this declaration and if called as a witness, I could and would

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competently testify to them.

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2.

I have read and reviewed the Declaration of Laszlo Bock also filed concurrently

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herewith, which describes the competitive harm that Google would suffer if information in the

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Declaration of William Campbell were made public. Specifically, Mr. Bock testified that were

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this information made public Google’s competitors would discover and therefore better

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understand, the unique and confidential arrangement between Mr. Campbell and Google

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regarding his role as senior advisor to Google, including how this arrangement was formalized

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and documented and the details and express terms and conditions of that arrangement (such as

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the specific manner in which Mr. Campbell has been, and continues to be, compensated for his

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work as a senior advisor to Google).

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3.

I have also read and reviewed Google’s Opposition to Plaintiffs’ Motion to

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Compel. The proposed redactions to the Opposition contain or quote information from the

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Declaration of William Campbell.

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4.

Accordingly, and for the reasons articulated in the Declaration of Lazlo Bock,

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these excerpts contain highly confidential information, and Google would suffer competitive

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harm if such excerpts were made public.

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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.

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_s/ Eric B. Evans___________________
Eric B. Evans

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DECL. OF ERIC B. EVANS ISO GOOGLE’S ADMIN. MOTION TO SEAL
MASTER DOCKET NO. 11-CV-2509-LHK