Unites States of America v. Apple, Inc. et al

Filing 329

BRIEF In Support of Plaintiffs' Proposed Injunction. Document filed by Unites States of America. (Attachments: # 1 Exhibit Plaintiffs' Proposed Final Judgment, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit)(Buterman, Lawrence)

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EXHIBIT 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------x UNITED STATES OF AMERICA, Plaintiff, vs. CASE NO. 12-CV-2826(DLC) APPLE INC., et. al, Defendants. --------------------------------x **HIGHLY CONFIDENTIAL** VIDEOTAPED DEPOSITION OF KEVIN SAUL FRIDAY, FEBRUARY 22, 2013 9:11 A.M. REPORTED BY: KIMBERLEE SCHROEDER, CSR, RPR, CCRR JOB NO. 28893 KEVIN SAUL - HIGHLY CONFIDENTIAL 52 1 10:28:51 2 10:28:53 general training regarding antitrust compliance while 3 10:28:57 at Apple? 4 10:28:58 A. I don't recall. 5 10:29:01 Q. Do you recall ever receiving, again, general 6 10:29:07 7 10:29:12 A. I don't recall. 8 10:29:13 Q. Do you receive any training of any kind at 9 10:29:17 10 10:29:18 11 10:29:31 12 10:29:37 13 10:29:39 appropriate workplace conduct? 14 10:29:42 may receive training on? 15 10:29:44 A. That one is a possibility, sure. 16 10:29:48 Q. But you, sitting here today, you don't know 17 10:29:51 18 10:29:52 A. Do what? 19 10:29:53 Q. Sitting here today, do you know whether for 20 10:29:56 sure you receive any training on appropriate workplace 21 10:29:59 conduct? 22 10:29:59 A. I don't recall. 23 10:30:00 Q. A fair amount of your work involves -- and I 24 10:30:06 apologize. 25 10:30:09 hand. Can you tell me whether you received any antitrust compliance training? Apple? A. General training -- general training, yes, in areas that may impact the business. Q. For example, you may receive training on Is that an area you whether for sure you do? You see what I'm doing. I'm using my DAVID FELDMAN WORLDWIDE, INC. 450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099 KEVIN SAUL - HIGHLY CONFIDENTIAL 211 1 REPORTER'S CERTIFICATE 2 3 I, KIMBERLEE SCHROEDER, CSR 11414, duly 4 authorized to administer oaths pursuant to Section 5 30(c) of the Federal Rules of Civil Procedure, hereby 6 certify that the witness in the foregoing deposition 7 was by me duly sworn to testify the truth, the whole 8 truth and nothing but the truth in the within-entitled 9 cause; that said deposition was taken at the time and 10 place therein stated; that the testimony of the said 11 witness was reported by me and thereafter transcribed 12 by me and that the witness was given an opportunity to 13 read and correct said deposition and to subscribe the 14 same. 15 I further certify that I am not of counsel or 16 attorney for either or any of the parties to said 17 cause of action, nor in any way interested in the 18 outcome of the cause named in said cause of action. 19 I declare under penalty of perjury under the 20 laws of the State of California that the foregoing is 21 true and correct. 22 Dated this 24th day of February, 2013. 23 24 25 KIMBERLEE SCHROEDER, CSR, RPR, CCRR DAVID FELDMAN WORLDWIDE, INC. 450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099

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