Unites States of America v. Apple, Inc. et al
DECLARATION of THEODORE J. BOUTROUS, JR. in Support re: 411 Objection (non-motion). Document filed by Apple, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P)(Boutrous, Theodore)
Tuesday, November 12, 2013 3:10 PM
Boutrous Jr., Theodore J.
Nigro, Barry (Barry.Nigro@friedfrank.com); Cirincione, Maria
(Maria.Cirincione@friedfrank.com); Richman, Cynthia; Swanson, Daniel G.
Thanks very much for your timely response and the offer of interviews with Mr. Moyer and Mr. Levoff
next Monday, November 18. We accept. We are hopeful that once you advise the company that we
will be conducting these interviews on Monday, other people whom we have identified, or whom you
have suggested, will become available on Monday, Tuesday, or even Wednesday. I think it is very
much in the company's interests for us to meet, if only briefly, those people with whom we will be
having the most contact over the next two years.
Please let us know whether we should be prepared to conduct the interviews Monday morning or
Monday afternoon. Also, we would very much appreciate obtaining the materials we originally
requested on October 22, especially those most relevant to Mr. Moyer's and Mr. Levoff's
responsibilities, as soon as possible.
Please let us know if the company has any suggestions on hotels where we should try to make
Again, thanks very much for your cooperation in this matter.
On Tue, Nov 12, 2013 at 4:55 PM, Boutrous Jr., Theodore J. wrote:
It was good speaking with you yesterday. I have
confirmed that Apple would be able to make available for 1-hour
intenrviews on Monday November 18 Tom Moyer, who is Chief
Compliance Officer and Head of Global Security, and Gene Levoff,
who serves as Senior Director, Associate General Counsel - Corporate
Law - and Assistant Secretary, Legal Counsel to Audit and
Nominating and Corporate Governance Committee, Liaison to Board
of Directors, and Counsel to Risk Management Committee. While
they would be able to cover many of the topics you have expressed
interest in discussing at the outset of your work, we strongly
encourage you to hold off and make the trip the week of December 2
or December 9, when Apple can make a fuller slate of folks available
to you, including Bruce Sewell, who will be attending the Samsung
trial next week, and Deena Said, the new Antitrust Compliance
Officer, who will be starting her job at the company and attending
new employee orientation next week, along with other relevant
members of the legal and business teams mentioned in my prior
correspondence. Apple respectfully submits that this will be more
efficient and effective in getting you the information you seek and in
working together to ensure that the company has comprehensive and
effective antitrust compliance and training programs. Regards,
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