In re: High-Tech Employee Antitrust Litigation

Filing 716

Omnibus Declaration of Christina J. Brown in Support of #715 Reply re Joint Motion to Exclude the Expert Testimony of Edward E. Leamer, Ph.D. , #714 Reply to Joint Motion to Strike the Improper Rebuttal Testimony in Dr. Leamer's Reply Expert Report or, in the Alternative, MOTION for Leave to Submit a Reply Report of Dr. Stiroh filed by Apple Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q)(Related document(s) #715 , #714 ) (Brown, Christina) (Filed on 2/27/2014) Modified text on 2/28/2014 (dhmS, COURT STAFF).

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GEORGE A. RILEY (Bar No. 118304)
[e-mail]
MICHAEL F. TUBACH (Bar No. 145955)
[e-mail]
CHRISTINA J. BROWN (Bar No. 242130)
[e-mail]
O’MELVENY & MYERS LLP
Two Embarcadero Center, 28th Floor
San Francisco, CA 94111-3823
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendant Apple 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

Master Docket No. 11-CV-2509 LHK

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OMNIBUS DECLARATION OF
CHRISTINA J. BROWN IN SUPPORT
OF DEFENDANTS’ REPLIES IN
SUPPORT OF JOINT MOTION TO
EXCLUDE TESTIMONY OF EDWARD
E. LEAMER, PH.D. AND JOINT
MOTION TO STRIKE IMPROPER
REBUTTAL TESTIMONY IN DR.
LEAMER’S REPLY EXPERT REPORT

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Date:

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Time:
Courtroom:
Judge:

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THIS DOCUMENT RELATES TO:
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ALL ACTIONS
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March 20, 2014 and
March 27, 2014
1:30 p.m.
8, 4th Floor
The Honorable Lucy H. Koh

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OMNIBUS BROWN DECL. ISO REPLIES ISO
MOTIONS TO EXCLUDE AND STRIKE
NO. 11-CV-2509-LHK

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I, Christina J. Brown, declare as follows:

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I am a member of the Bar of the State of California and a counsel at O’Melveny &

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Myers LLP, attorneys for Defendant Apple Inc. I submit this declaration in support of

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Defendants’ Replies in Support of Joint Motion to Exclude the Expert Testimony of Edward E.

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Leamer, Ph.D. and Joint Motion to Strike the Improper Rebuttal Testimony in Dr. Leamer’s

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Reply Expert Report or, in the Alternative, for Leave to Submit a Reply Report of Dr. Stiroh.

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I make this declaration based on my own personal knowledge. If called to testify as a witness,

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I could and would do so competently.

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2.

Attached hereto as Exhibit A is a true and correct copy of the November 12, 2012

Expert Report of Professor Kevin M. Murphy.
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Attached hereto as Exhibit B is a true and correct copy of excepts from the

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October 26, 2012, November 18, 2013, and December 19, 2013 deposition testimony of Dr.

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Edward Leamer.

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4.

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Attached hereto as Exhibit C is a true and correct copy of excerpts from the

December 3, 2012 deposition testimony of Dr. Kevin Murphy.
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Attached hereto as Exhibit D is a true and correct copy of excerpts from the

December 9, 2013 deposition testimony of Dr. Lauren Stiroh.
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Attached hereto as Exhibit E is a true and correct copy of excerpts from the

January 29, 2013 deposition testimony of Paul Otellini.
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Attached hereto as Exhibit F is a true and correct copy of a document produced by

Google bearing Bates number GOOG-HIGH-TECH-00058864.
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Attached hereto as Exhibit G is a true and correct copy of excerpts from the

Federal Judicial Center, Reference Manual on Scientific Evidence (3d ed. 2011).
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Attached hereto as Exhibit H is a true and correct copy of excerpts from

Understanding and Using Advanced Statistics (2006).
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Attached hereto as Exhibit I is a true and correct copy from the STATA Manual -

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Stata 13 help for regress. The document was printed from http://www.stata.com/help.cgi?regress,

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which was last visited on February 27, 2014.
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OMNIBUS BROWN DECL. ISO REPLIES ISO
MOTIONS TO EXCLUDE AND STRIKE
NO. 11-CV-2509-LHK

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Attached hereto as Exhibit J is a true and correct copy of excerpts from Statistics

in a Nutshell (1st ed. 2008).
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Attached hereto as Exhibit K is a true and correct copy of excerpts from A Guide

to Modern Econometrics (2d ed. 2004).
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Attached hereto as Exhibit L is a true and correct copy of excerpts from A Course

in Econometrics (1991).
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Attached hereto as Exhibit M is a true and correct copy of excerpts from Proving

Antitrust Damages, Legal and Economic Issues (2d ed. 2010).
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Attached hereto as Exhibit N is a true and correct copy of excerpts from Principles

of Econometrics (4th ed. 2011).
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Attached hereto as Exhibit O is a true and correct copy of excerpts from

Microeconometrics, Methods and Applications (2005).
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Attached hereto as Exhibit P is a true and correct copy of Multicountry,

Multifactor Tests of the Factor Abundance Theory, The American Economic Review (Dec. 1987).
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Attached hereto as Exhibit Q is a true and correct copy of Sets of Posterior Means

with Bounded Variance Priors, Econometrica (May 1982).

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I declare under penalty of perjury under the laws of the United States that the above is true
and correct. Executed on February 27, 2014, in San Francisco, California.

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/s/ Christina J. Brown
Christina J. Brown

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OMNIBUS BROWN DECL. ISO REPLIES ISO
MOTIONS TO EXCLUDE AND STRIKE
NO. 11-CV-2509-LHK