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

Filing 93

DECLARATION of Claudia Ray in Opposition re: 68 MOTION to Preclude the Testimony of Defendant's Expert Witness Gregory S. Carpenter.. Document filed by Apple Inc.. (Attachments: # 1 Tab - Carpenter Dep, # 2 Tab - McDonald Dep)(Cendali, Dale)

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-----------------------------X
J.T. COLBY & COMPANY, INC.,
d/b/a BRICK TOWER PRESS,
J. BOYLSTON & COMPANY
PUBLISHERS LLC and
IPICTUREBOOKS LLC,
Plaintiffs,
vs.

No. 11-cv-4060 (DLC)

APPLE, INC.,
Defendant.
-----------------------------X

November 21, 2012
9:31 a.m.

Videotaped deposition of GREGORY
S. CARPENTER, Ph.D., held at the offices
of Quinn Emanuel Urquhart & Sullivan LLP,
51 Madison Avenue, New York, New York,
pursuant to Agreement, before Theresa
Tramondo, a Notary Public of the State of
New York.

Job No: 27811

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Carpenter

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Q.

You disagree, okay.
So you think no matter what

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industry is on the table, you are capable of

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providing an opinion with respect to various

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issues in that industry, right?

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A.

With enough analysis, yes.

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Q.

And so you've not ever been

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employed in the book publishing industry,
have you?

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A.

I've not.

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Q.

And you've not ever consulted for a

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book publisher, have you?
A.

I've provided executive seminars

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for people in magazine publishing and media

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and related businesses and many businesses

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that have characteristics associated with

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book publishing.

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Q.

Did you mention magazine

publishing?

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A.

I did.

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Q.

You gave a seminar?

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A.

I did.

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Q.

When?

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A.

I've given a number of them over
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