J.T. Colby & Company, Inc. et al v. Apple, Inc.

Filing 69

DECLARATION of Claudia T. Bogdanos in Support re: 68 MOTION to Preclude the Testimony of Defendant's Expert Witness Gregory S. Carpenter.. Document filed by Ipicturebooks LLC, J.Boyston & Company, J.T. Colby & Company, Inc., Publishers LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Chattoraj, Partha)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
____________________________________
J.T. COLBY & COMPANY, INC. d/b/a/
BRICKTOWER PRESS, J. BOYLSTON &
COMPANY, PUBLISHERS LLC and
IPICTUREBOOKS LLC,
Plaintiffs,
-againstAPPLE INC.,
Defendant.

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Case No. 11 Civ. 4060 (DLC)

DECLARATION OF CLAUDIA T. BOGDANOS
IN SUPPORT OF PLAINTIFFS’ MOTION TO EXCLUDE THE TESTIMONY
OF DEFENDANT’S EXPERT WITNESS GREGORY S. CARPENTER
I, Claudia T. Bogdanos, pursuant to 28 U.S.C. § 1746, declare as follows:
1.

I am over 18 years old and I am competent to make this declaration based upon

my personal knowledge. I make this Declaration in support of Plaintiffs’ Motion To Exclude
The Testimony, Including Affidavits, Declarations, And Reports, Of Defendant’s Expert Witness
Gregory S. Carpenter, cited in the accompanying memorandum of law.
2.

I am an attorney at Quinn Emanuel Urquhart & Sullivan, LLP. I am admitted to

the New York bar and am currently in good standing.
3.

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

Expert Report of Gregory S. Carpenter in this matter, dated September 17, 2012.
4.

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

Rebuttal Expert Report of Gregory S. Carpenter in this matter, dated October 26, 2012.

1

5.

Attached hereto as Exhibit C is a true and correct copy

of

excerpts from the

21,2012'
transcript of the deposition of Gregory S. Carpenter, datedNovember

6.

Attached hereto as Exhibit

D is a true and correct copy of

excerpts &om the

Expert Report of Mike shatzkin in this matter, dated october 24,2012-

I declare under penalty of perjury under the laws of the United
foregoing is true and correct.
Executed this 21st day of December, 2012'

States of America that the