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)

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.
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**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

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10:28:51

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10:28:53

general training regarding antitrust compliance while

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10:28:57

at Apple?

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10:28:58

A.

I don't recall.

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10:29:01

Q.

Do you recall ever receiving, again, general

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10:29:07

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10:29:12

A.

I don't recall.

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10:29:13

Q.

Do you receive any training of any kind at

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10:29:17

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10:29:18

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10:29:31

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10:29:37

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10:29:39

appropriate workplace conduct?

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10:29:42

may receive training on?

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10:29:44

A.

That one is a possibility, sure.

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10:29:48

Q.

But you, sitting here today, you don't know

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10:29:51

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10:29:52

A.

Do what?

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10:29:53

Q.

Sitting here today, do you know whether for

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10:29:56

sure you receive any training on appropriate workplace

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10:29:59

conduct?

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10:29:59

A.

I don't recall.

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10:30:00

Q.

A fair amount of your work involves -- and I

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10:30:06

apologize.

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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

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REPORTER'S CERTIFICATE

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I, KIMBERLEE SCHROEDER, CSR 11414, duly

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authorized to administer oaths pursuant to Section

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30(c) of the Federal Rules of Civil Procedure, hereby

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certify that the witness in the foregoing deposition

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was by me duly sworn to testify the truth, the whole

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truth and nothing but the truth in the within-entitled

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cause; that said deposition was taken at the time and

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place therein stated; that the testimony of the said

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witness was reported by me and thereafter transcribed

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by me and that the witness was given an opportunity to

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read and correct said deposition and to subscribe the

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same.

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I further certify that I am not of counsel or

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attorney for either or any of the parties to said

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cause of action, nor in any way interested in the

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outcome of the cause named in said cause of action.

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I declare under penalty of perjury under the

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laws of the State of California that the foregoing is

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true and correct.

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Dated this 24th day of February, 2013.

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KIMBERLEE SCHROEDER, CSR, RPR, CCRR

DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099