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

Filing 426

DECLARATION of CYNTHIA E. RICHMAN in Support re: 425 Letter. Document filed by Apple, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F)(Boutrous, Theodore)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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UNITED STATES OF AMERICA,
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:
Plaintiff,
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:
v.
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APPLE INC., et al.,
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Defendants.
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THE STATE OF TEXAS,
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THE STATE OF CONNECTICUT, et al.,
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Plaintiffs,
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v.
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PENGUIN GROUP (USA) INC., et al.,
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Defendants.
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:
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12 Civ. 2826 (DLC)

12 Civ. 03394 (DLC)

DECLARATION OF CYNTHIA E. RICHMAN

I, CYNTHIA E. RICHMAN, pursuant to 28 U.S.C. § 1746, declare:
1.

I am an attorney duly licensed to practice law in the District of Columbia and

State of Maryland. I have been given permission to appear before the United States District
Court for the Southern District of New York pro hac vice. I am a partner at Gibson, Dunn &
Crutcher LLP and am one of the attorneys representing Apple Inc. in the above-captioned
matter. I respectfully submit this declaration in support of Apple’s January 7, 2014 letter to the
Court regarding its objections to the External Compliance Monitor. I have personal knowledge
of the matters stated herein and, if called upon to do so, could and would competently testify
thereto.
2.

Attached hereto as Exhibit A is a true and correct copy of a letter from Theodore

J. Boutrous, Jr. to J. Robert Kramer, II and Gabriel Gervey, sent on October 31, 2013.
3.

Attached hereto as Exhibit B is a true and correct copy of a letter from Theodore

J. Boutrous, Jr. to Lawrence E. Buterman and Gabriel Gervey, sent on November 27, 2013.
4.

Attached hereto as Exhibit C is a true and correct copy of a letter from Theodore

J. Boutrous, Jr. to Lawrence E. Buterman and Gabriel Gervey, sent on December 6, 2013.
5.

Attached hereto as Exhibit D is a true and correct copy of a letter from Noreen

Krall to Lawrence E. Buterman and Eric Lipman, sent on December 17, 2013.
6.

Attached hereto as Exhibit E is a true and correct copy of a letter from Theodore

J. Boutrous, Jr. to Lawrence E. Buterman and Gabriel Gervey, sent on December 21, 2013.
7.

Attached hereto as Exhibit F is a true and correct copy of a letter from Theodore

J. Boutrous, Jr. to Lawrence E. Buterman and Gabriel Gervey, sent on January 3, 2014.

2

I declare under penalty of perjury, under the laws of the United States, that the
foregoing is true and correct.
Dated: January 7, 2014

Respectfully submitted,

ynthia E. Richman