UNITED STATES OF AMERICA v. AT&T INC. et al

Filing 95

MOTION to Quash Subpoena by LIGHTSQUARED GP, INC. (Attachments: # 1 Declaration of Patricia Robbins, # 2 Exhibit A to Declaration, # 3 Exhibit B to Declaration, # 4 Exhibit C to Declaration, # 5 Exhibit D to Declaration, # 6 Text of Proposed Order)(jf, )

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

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UNITED STATES OF AMERICA, et al.,

Plaintiffs,
v.

AT&T iNC., et

a!.,

Defendants.

CaseNo. 1:11-cv-01560-ESH

________________________________________________________________________________)

DECLARATION OF PATRICIA C. ROBBINS IN SUPPORT OF
NON-PARTY LIGHTSQUARED GP, INC.’S MOTION TO QUASH

I, Patricia C. Robbins, declare
1.

I

could and would
2.

Virginia,

I

am

follows:

familiar with the facts set forth herein and, if called and

testify competently
am

as

a

and from

personal knowledge

as

to the

sworn as a

following

witness,

I

matters.

member of the Bars of the State of New York, the Commonwealth of

and the District of Columbia, and I

am

an

associate in the law firm of Latham &

Watkins, LLP, counsel for non-party LightSquared GP, Inc. (“LightSquared”).
3.

LightSquared
on

On

a

or

about

subpoena

November

that commanded

November 29, 2011, pursuant to Rule
4.

On November

14,

defendant

LightSquared

to

30(b)(6). (Attached

testify
hereto

AT&T,
at

as

a

Inc.

deposition

Exhibit

served

upon

to take

place

A).

29, 2011, counsel for LightSquared, counsel for defendants AT&T,

T-Mobile USA, Inc., and Deutsche Telekom AG
U.S.

2011,

Department of Justice, Antitrust

(collectively, “defendants”),

Division executed

a

and counsel for the

letter agreement that, among other

things, scheduled

LightSquared deposition

the

for December 7, 2011.

hereto

(Attached

as

Exhibit B).
On December 5, 2011, counsel for

5.
DOJ

requesting

of their

made

that the December 7

applications

by

6.

(Attached

Angstreich

that

suggested

hereto
after

Shortly

with Scott

be

sent

in

light

postponed

to the Federal Communications Commission

AT&T which

transaction.

deposition

LightSquared

as

Exhibit

sending

AT&T

might

a

letter to defendants and

of defendants’ withdrawal

(“FCC”) and public

abandon

or

materially change

the above-referenced letter

on

December 5, 2011, I

Kellogg, Huber, Hansen, Todd,

P.L.L.C., counsel for AT&T. Mr. Angstreich stated that defendants would

AT&T’s

In

position. (Attached
I declare under

Executed this 6th

day

a

letter transmitted

hereto

penalty

as

the

C).

from the law firm of

LightSquared’s deposition.

statements

Exhibit

on

the

same

Evans &

not agree to

foregoing

Figel,

postpone

date, Mr. Angstreich reconfirmed

D).

of perjury that the

spoke

is true and correct.

of December, 2011.

Patricia C. Robbins