Brief in Support to [165] MOTION for Entry of Order Regarding Coordination of Discovery filed by Commonwealth of Virginia, State of Arizona, State of California, State of Colorado, State of Connecticut, State of Illinois, State of Michigan, State of Minnesota, State of Nebraska, State of New Hampshire, State of New Jersey, State of New York, State of North Carolina, State of Rhode Island, State of Tennessee, State of Washington, State of West Virginia, United States of America. (Teitelbaum, Aaron)
Page 1 PageID#
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES, et al.,
v.
Plaintiffs,
GOOGLE LLC,
Defendant.
)
)
)
)
)
)
)
)
No. 1:23-cv-00108-LMB-JFA
PLAINTIFFS’ BRIEF IN SUPPORT OF MOTION FOR ENTRY OF ORDER
REGARDING COORDINATION OF DISCOVERY
The United States and eight states initiated this action against Google in January 2023,
ECF No. 1, and nine additional states joined with the filing of an amended complaint in April
2023, ECF No. 120. A multidistrict litigation pending against Google in the U.S. District Court
for the Southern District of New York (“MDL”) with certain similar claims and facts preceded
this action. See generally In re Google Dig. Advert. Antitrust Litig., 21-md-3010-PKC
(S.D.N.Y.). The Court denied Google’s motion to transfer this action to the Southern District of
New York, finding that “Congress’s clear intent to prioritize speedy and efficient resolution of
government antitrust suits” outweighed concerns about “duplication of effort and use of judicial
resources” stemming from this action remaining in this District. Memo. Op. Mot. Transfer, ECF
No. 60, 18.
Having prevailed on the motion to transfer, plaintiffs nonetheless engaged in negotiations
with Google over the possible coordination of discovery with the MDL to conserve judicial
resources and the resources of non-parties where possible, while ensuring that no party receives
an unfair strategic advantage (or disadvantage) as a result of the coordination. Those negotiations
have yielded the proposed order at ECF No. 166-1 (“Proposed Order”), which contains
substantial areas of agreement between plaintiffs and Google regarding the management ofPage 2 PageID#
discovery in this case and the MDL. Plaintiffs largely agree with Google that the remaining areas
of dispute, noted in the proposed order in brackets, fall into three categories: (1) the appropriate
use of discovery obtained in the MDL after the end of fact discovery in this action; (2) the ability
to participate in depositions; and (3) the allocation of time at depositions. The Court should adopt
plaintiffs’ proposals on these disputed issues because they maintain a level playing field among
all parties while still allowing for an appropriate degree of coordination between this case and
the MDL.
ARGUMENT
I.
Plaintiffs’ Proposed Ground Rules for Use of Depositions, Documents, and Data
from the MDL Are Consistent with the Discovery Plan and Maintain a Level Playing
Field in This Action, While Google’s Proposals Would Effectively Make the Fact
Discovery Cutoff in This Case Applicable Only to Plaintiffs.
The first area of disagreement concerns the use of depositions, documents, and data
obtained in the MDL after the fact discovery cutoff in this action. Proposed Order ¶¶ 2.e, 6.d.
A.
Use of Documents and Data Obtained After the Fact Discovery Cutoff in
This Case
Plaintiffs’ position is that documents and data produced in the MDL after the fact
discovery cutoff in this case should only be usable here for impeachment purposes, and only if
they are produced to plaintiffs within 14 days of receipt in the MDL. Proposed Order ¶ 2.e.
Google’s position is that there should be no such limitations on the use of documents and data.
Google’s position is untenable in light of the fact discovery cutoff of September 8, 2023, in this
case. ECF No. 94. Currently, the fact discovery cutoff in the MDL is June 28, 2024, just under
10 months later. In re Google Dig. Advert. Antitrust Litig., 21-md-3010-PKC, ECF No. 394.
Google’s position as a party in both this case and the MDL would allow it to continue to obtain
relevant documents and data in the MDL, and then use them at trial in this action, while plaintiffs Page 3 PageID#
here would be precluded from additional fact discovery after the cutoff this September. In effect,
the discovery cutoff in this case would apply only to plaintiffs and not Google. This arrangement
would be inconsistent with “the spirit behind the discovery rules, which is to promote a liberal
discovery process in an effort to narrow the issues for trial and to prevent unfair surprise.” L.A.
Terminals, Inc. v. United Nat’l Ins. Co., 340 F.R.D. 390, 396 (C.D. Cal. 2022) (quoting Episcopo
v. Gen. Motors Corp., 2004 WL 628243, *7 (N.D. Ill. Mar. 29, 2004)) (emphasis added); see
also Russell v. Absolute Collection Servs., Inc., 763 F.3d 385, 396 (4th Cir. 2014) (noting that the
purpose of Rule 26(a) is to “allow the parties to adequately prepare their cases for trial and to
avoid unfair surprise”).
Google argues that its position is preferable because it “erects no obstacles to probative
evidence being used” in this case, Google Br. 6, ECF No. 166 (“Google Br.”), but this Court
imposed a fact discovery cutoff on all parties, not just plaintiffs, see ECF No. 94. It would be
unfairly prejudicial to plaintiffs to permit Google to continue gathering evidence in support of its
defenses while plaintiffs’ hands are tied. See Gordon v. Target Corp., 318 F.R.D. 242, (E.D.N.Y. 2016) (noting that the “over-arching purpose of the discovery rules is to encourage the
disclosure of information and materials to avoid unnecessary surprise and to level the playing
field for both parties to the litigation” (citation omitted)).
B.
Use of Depositions Taken in the MDL After the Fact Discovery Cutoff in
This Case
Like with documents and data, Google contends that depositions taken in the MDL after
the fact discovery cutoff here should be admissible “as if the depositions had been taken in both”
cases. Proposed Order ¶ 6.e. For substantially the same reasons as with documents and data, this
position would unfairly prejudice plaintiffs in this case. Additionally, Google’s position is at
odds with Federal Rule of Civil Procedure 32, which provides that a deposition may not be used Page 4 PageID#
at trial against a party unless the party “was present or represented at the taking of the deposition
or had reasonable notice of it.” Fed. R. Civ. P. 32(a)(1)(A). The fact discovery cutoff precludes
plaintiffs from being “present or represented” at a later MDL deposition. The “reasonable notice”
portion of the Rule is inapplicable because it contemplates a situation where a deposition is
scheduled with insufficient lead time for a party to attend or obtain counsel, not a situation
where, as here, a discovery cutoff precludes plaintiffs from participating. See Wright & Miller,
Federal Practice & Procedure § 2147.1 (discussing “reasonable notice” component of Rule
32(a)(1)(A)). Here, Google would preserve for itself the right to use affirmatively testimony
from MDL fact depositions at which plaintiffs in this case had no opportunity to participate or
examine the witness. Such a result would undermine the parity contemplated by the Federal
Rules of Civil Procedure and would be fundamentally unfair to plaintiffs.
The Court should instead adopt plaintiffs’ proposal because it preserves all parties’ ability
to impeach witnesses based on their sworn deposition testimony, but maintains adherence to the
discovery cutoff for all parties, not just plaintiffs. This arrangement treats all parties equally and
reduces the chance of unfair surprise at trial. See, e.g., Gordon, 318 F.R.D. at 246. II.
Plaintiffs’ Proposals Regarding Participation in Depositions Treat the MDL and
This Action As Coordinated With Respect to All Parties, Not Just Google.
Plaintiffs’ position on participation in depositions treats a deposition noticed in either
case as if it were noticed in both cases. See Proposed Order ¶¶ 4-5. This position is consistent
Plaintiffs agree with Google that the handling of expert reports is not yet ripe for resolution,
and can be addressed in the first instance through the meet and confer process. Google Br. 7, n.7.
The point of disagreement relates, once again, to maintaining a level playing field. Plaintiffs’
position requires sharing of expert reports that are issued in the MDL while this action is
pending, to ensure that Google’s experts cannot take contradictory positions in the MDL versus
here. Google’s position leaves open the possibility that it could serve an expert report in the
MDL shortly before trial in this action without prior notice to plaintiffs here, and plaintiffs here
would have no ability to evaluate whether the positions taken in that report are consistent with
Google’s positions in this case. Page 5 PageID#
with the dual purposes of minimizing duplication of effort across cases while maintaining a level
playing field for all parties. Google’s position, by contrast, tilts the benefits of coordination
toward itself. See id. The Court should adopt plaintiffs’ position.
An example illustrates why plaintiffs’ position is more reasonable and should prevail. If
only one party notices a deposition of a nonparty, and no other party cross notices the deposition,
plaintiffs’ position permits all remaining parties—in both cases—the opportunity to ask
questions for a total of one hour, divided among themselves, just as if the deposition had been
noticed in both cases. Proposed Order ¶ 5.a. Google seeks to retain separation between the cases
by permitting participation in that one hour of questioning only by the remaining parties in the
case where the deposition was noticed. Id. Of course, Google is the only entity that is a party in
both cases. So, the practical effect of Google’s proposal is that it will always get to participate in
that one hour of examination, while other parties will only sometimes get to participate. Because
Google, and no other party, has optionality in deciding in which case to notice a deposition, it
alone can control who participates at the deposition, while no other party can do so.
Google argues that its position is appropriate because, in the absence of a coordination
order, it would be able to participate in depositions in both cases without having to share time
with parties from both cases, and would be able to notice depositions in both cases. Google Br.
4-5. The problem with Google’s argument is that it has chosen to seek a coordination order, and
has joined with plaintiffs in proposing such an order to the Court. The question now before the
Court is, to the extent that it chooses to enter a coordination order, how to coordinate discovery
to promote the dual interests of efficiency and fairness. A coordination order that preserves all of
Google’s advantages in the absence of coordination, while conferring yet more advantages on
Google and no benefit on any other party does not serve these dual interests. Page 6 PageID#
III.
Plaintiffs’ Proposals Regarding Deposition Time Allocations Are Fair to All Parties
in Both Cases.
Plaintiffs’ proposals on deposition time already confer a substantial benefit on Google by
ensuring that a Google witness will only be deposed once, on two consecutive days. See
Proposed Order ¶ 4. A Google witness will therefore only have to prepare to be deposed once,
and will not face the challenge of answering questions on the same topic in two separate
depositions separated by months. Third parties will receive the same benefit, plus reductions in
total deposition time depending on how many parties notice the deposition. Id. ¶ 5. Plaintiffs’
proposals otherwise allocate time equally across all parties in both cases, based only on whether
a party has noticed (or cross noticed) a deposition. The Court should adopt plaintiffs’ proposals
because they treat all parties equally.
Google suggests that plaintiffs’ proposals extend Google depositions beyond the
“default” of seven hours, Google Br. 5-6, but Google ignores—only for this one point—that it is
a defendant in two cases, and so is subject to having its personnel deposed on two separate
occasions in the absence of a coordination order. Plaintiffs have asserted their right to litigate in
this forum, and the Court appropriately rejected Google’s request to have this case adjudicated
alongside the MDL. Plaintiffs here should receive a full allotment of time to depose Google
witnesses to ensure the effective prosecution of this enforcement action. In light of the benefits to
Google of its personnel being deposed only once, this is a reasonable outcome. Google should
not receive the added benefit of reduced total deposition time for its current and former
employees. Page 7 PageID#
CONCLUSION
Plaintiffs respectfully request that the Court adopt their proposals in the Proposed Order,
and otherwise enter the Proposed Order as jointly proposed by plaintiffs and Google.
Dated: May 4, Respectfully submitted,
JESSICA D. ABER
United States Attorney
JASON S. MIYARES
Attorney General of Virginia
/s/ Gerard Mene
GERARD MENE
Assistant U.S. Attorney
2100 Jamieson Avenue
Alexandria, VA Telephone: (703) 299-Facsimile: (703) 299-Email: Gerard.Mene@usdoj.gov
/s/ Andrew N. Ferguson
ANDREW N. FERGUSON
Solicitor General
STEVEN G. POPPS
Deputy Attorney General
TYLER T. HENRY
Assistant Attorney General
/s/ Julia Tarver Wood
JULIA TARVER WOOD
/s/ Aaron M. Teitelbaum
AARON M. TEITELBAUM
United States Department of Justice
Antitrust Division
450 Fifth Street NW, Suite Washington, DC Telephone: (202) 307-Fax: (202) 616-Email: Julia.Tarver.Wood@usdoj.gov
Attorneys for the United States
Office of the Attorney General of Virginia
202 North Ninth Street
Richmond, VA Telephone: (804) 692-Facsimile: (804) 786-Email: thenry@oag.state.va.us
Attorneys for the Commonwealth of
Virginia and local counsel for the
States of Arizona, California,
Colorado, Connecticut, Illinois,
Michigan, Minnesota, Nebraska, New
Hampshire, New Jersey, New York,
North Carolina, Rhode Island,
Tennessee, Washington, and West
Virginia
PDF Page 1
PlainSite Cover Page
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Case 1:23-cv-00108-LMB-JFA Document 174 Filed 05/04/23 Page 1 of 7 PageID# 1330
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES, et al.,
v.
Plaintiffs,
GOOGLE LLC,
Defendant.
)
)
)
)
)
)
)
)
No. 1:23-cv-00108-LMB-JFA
PLAINTIFFS’ BRIEF IN SUPPORT OF MOTION FOR ENTRY OF ORDER
REGARDING COORDINATION OF DISCOVERY
The United States and eight states initiated this action against Google in January 2023,
ECF No. 1, and nine additional states joined with the filing of an amended complaint in April
2023, ECF No. 120. A multidistrict litigation pending against Google in the U.S. District Court
for the Southern District of New York (“MDL”) with certain similar claims and facts preceded
this action. See generally In re Google Dig. Advert. Antitrust Litig., 21-md-3010-PKC
(S.D.N.Y.). The Court denied Google’s motion to transfer this action to the Southern District of
New York, finding that “Congress’s clear intent to prioritize speedy and efficient resolution of
government antitrust suits” outweighed concerns about “duplication of effort and use of judicial
resources” stemming from this action remaining in this District. Memo. Op. Mot. Transfer, ECF
No. 60, 18.
Having prevailed on the motion to transfer, plaintiffs nonetheless engaged in negotiations
with Google over the possible coordination of discovery with the MDL to conserve judicial
resources and the resources of non-parties where possible, while ensuring that no party receives
an unfair strategic advantage (or disadvantage) as a result of the coordination. Those negotiations
have yielded the proposed order at ECF No. 166-1 (“Proposed Order”), which contains
substantial areas of agreement between plaintiffs and Google regarding the management of
PDF Page 3
Case 1:23-cv-00108-LMB-JFA Document 174 Filed 05/04/23 Page 2 of 7 PageID# 1331
discovery in this case and the MDL. Plaintiffs largely agree with Google that the remaining areas
of dispute, noted in the proposed order in brackets, fall into three categories: (1) the appropriate
use of discovery obtained in the MDL after the end of fact discovery in this action; (2) the ability
to participate in depositions; and (3) the allocation of time at depositions. The Court should adopt
plaintiffs’ proposals on these disputed issues because they maintain a level playing field among
all parties while still allowing for an appropriate degree of coordination between this case and
the MDL.
ARGUMENT
I.
Plaintiffs’ Proposed Ground Rules for Use of Depositions, Documents, and Data
from the MDL Are Consistent with the Discovery Plan and Maintain a Level Playing
Field in This Action, While Google’s Proposals Would Effectively Make the Fact
Discovery Cutoff in This Case Applicable Only to Plaintiffs.
The first area of disagreement concerns the use of depositions, documents, and data
obtained in the MDL after the fact discovery cutoff in this action. Proposed Order ¶¶ 2.e, 6.d.
A.
Use of Documents and Data Obtained After the Fact Discovery Cutoff in
This Case
Plaintiffs’ position is that documents and data produced in the MDL after the fact
discovery cutoff in this case should only be usable here for impeachment purposes, and only if
they are produced to plaintiffs within 14 days of receipt in the MDL. Proposed Order ¶ 2.e.
Google’s position is that there should be no such limitations on the use of documents and data.
Google’s position is untenable in light of the fact discovery cutoff of September 8, 2023, in this
case. ECF No. 94. Currently, the fact discovery cutoff in the MDL is June 28, 2024, just under
10 months later. In re Google Dig. Advert. Antitrust Litig., 21-md-3010-PKC, ECF No. 394.
Google’s position as a party in both this case and the MDL would allow it to continue to obtain
relevant documents and data in the MDL, and then use them at trial in this action, while plaintiffs
2
PDF Page 4
Case 1:23-cv-00108-LMB-JFA Document 174 Filed 05/04/23 Page 3 of 7 PageID# 1332
here would be precluded from additional fact discovery after the cutoff this September. In effect,
the discovery cutoff in this case would apply only to plaintiffs and not Google. This arrangement
would be inconsistent with “the spirit behind the discovery rules, which is to promote a liberal
discovery process in an effort to narrow the issues for trial and to prevent unfair surprise.” L.A.
Terminals, Inc. v. United Nat’l Ins. Co., 340 F.R.D. 390, 396 (C.D. Cal. 2022) (quoting Episcopo
v. Gen. Motors Corp., 2004 WL 628243, *7 (N.D. Ill. Mar. 29, 2004)) (emphasis added); see
also Russell v. Absolute Collection Servs., Inc., 763 F.3d 385, 396 (4th Cir. 2014) (noting that the
purpose of Rule 26(a) is to “allow the parties to adequately prepare their cases for trial and to
avoid unfair surprise”).
Google argues that its position is preferable because it “erects no obstacles to probative
evidence being used” in this case, Google Br. 6, ECF No. 166 (“Google Br.”), but this Court
imposed a fact discovery cutoff on all parties, not just plaintiffs, see ECF No. 94. It would be
unfairly prejudicial to plaintiffs to permit Google to continue gathering evidence in support of its
defenses while plaintiffs’ hands are tied. See Gordon v. Target Corp., 318 F.R.D. 242, 246
(E.D.N.Y. 2016) (noting that the “over-arching purpose of the discovery rules is to encourage the
disclosure of information and materials to avoid unnecessary surprise and to level the playing
field for both parties to the litigation” (citation omitted)).
B.
Use of Depositions Taken in the MDL After the Fact Discovery Cutoff in
This Case
Like with documents and data, Google contends that depositions taken in the MDL after
the fact discovery cutoff here should be admissible “as if the depositions had been taken in both”
cases. Proposed Order ¶ 6.e. For substantially the same reasons as with documents and data, this
position would unfairly prejudice plaintiffs in this case. Additionally, Google’s position is at
odds with Federal Rule of Civil Procedure 32, which provides that a deposition may not be used
3
PDF Page 5
Case 1:23-cv-00108-LMB-JFA Document 174 Filed 05/04/23 Page 4 of 7 PageID# 1333
at trial against a party unless the party “was present or represented at the taking of the deposition
or had reasonable notice of it.” Fed. R. Civ. P. 32(a)(1)(A). The fact discovery cutoff precludes
plaintiffs from being “present or represented” at a later MDL deposition. The “reasonable notice”
portion of the Rule is inapplicable because it contemplates a situation where a deposition is
scheduled with insufficient lead time for a party to attend or obtain counsel, not a situation
where, as here, a discovery cutoff precludes plaintiffs from participating. See Wright & Miller,
Federal Practice & Procedure § 2147.1 (discussing “reasonable notice” component of Rule
32(a)(1)(A)). Here, Google would preserve for itself the right to use affirmatively testimony
from MDL fact depositions at which plaintiffs in this case had no opportunity to participate or
examine the witness. Such a result would undermine the parity contemplated by the Federal
Rules of Civil Procedure and would be fundamentally unfair to plaintiffs.
The Court should instead adopt plaintiffs’ proposal because it preserves all parties’ ability
to impeach witnesses based on their sworn deposition testimony, but maintains adherence to the
discovery cutoff for all parties, not just plaintiffs. This arrangement treats all parties equally and
reduces the chance of unfair surprise at trial. See, e.g., Gordon, 318 F.R.D. at 246. 1
II.
Plaintiffs’ Proposals Regarding Participation in Depositions Treat the MDL and
This Action As Coordinated With Respect to All Parties, Not Just Google.
Plaintiffs’ position on participation in depositions treats a deposition noticed in either
case as if it were noticed in both cases. See Proposed Order ¶¶ 4-5. This position is consistent
1
Plaintiffs agree with Google that the handling of expert reports is not yet ripe for resolution,
and can be addressed in the first instance through the meet and confer process. Google Br. 7, n.7.
The point of disagreement relates, once again, to maintaining a level playing field. Plaintiffs’
position requires sharing of expert reports that are issued in the MDL while this action is
pending, to ensure that Google’s experts cannot take contradictory positions in the MDL versus
here. Google’s position leaves open the possibility that it could serve an expert report in the
MDL shortly before trial in this action without prior notice to plaintiffs here, and plaintiffs here
would have no ability to evaluate whether the positions taken in that report are consistent with
Google’s positions in this case.
4
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Case 1:23-cv-00108-LMB-JFA Document 174 Filed 05/04/23 Page 5 of 7 PageID# 1334
with the dual purposes of minimizing duplication of effort across cases while maintaining a level
playing field for all parties. Google’s position, by contrast, tilts the benefits of coordination
toward itself. See id. The Court should adopt plaintiffs’ position.
An example illustrates why plaintiffs’ position is more reasonable and should prevail. If
only one party notices a deposition of a nonparty, and no other party cross notices the deposition,
plaintiffs’ position permits all remaining parties—in both cases—the opportunity to ask
questions for a total of one hour, divided among themselves, just as if the deposition had been
noticed in both cases. Proposed Order ¶ 5.a. Google seeks to retain separation between the cases
by permitting participation in that one hour of questioning only by the remaining parties in the
case where the deposition was noticed. Id. Of course, Google is the only entity that is a party in
both cases. So, the practical effect of Google’s proposal is that it will always get to participate in
that one hour of examination, while other parties will only sometimes get to participate. Because
Google, and no other party, has optionality in deciding in which case to notice a deposition, it
alone can control who participates at the deposition, while no other party can do so.
Google argues that its position is appropriate because, in the absence of a coordination
order, it would be able to participate in depositions in both cases without having to share time
with parties from both cases, and would be able to notice depositions in both cases. Google Br.
4-5. The problem with Google’s argument is that it has chosen to seek a coordination order, and
has joined with plaintiffs in proposing such an order to the Court. The question now before the
Court is, to the extent that it chooses to enter a coordination order, how to coordinate discovery
to promote the dual interests of efficiency and fairness. A coordination order that preserves all of
Google’s advantages in the absence of coordination, while conferring yet more advantages on
Google and no benefit on any other party does not serve these dual interests.
5
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Case 1:23-cv-00108-LMB-JFA Document 174 Filed 05/04/23 Page 6 of 7 PageID# 1335
III.
Plaintiffs’ Proposals Regarding Deposition Time Allocations Are Fair to All Parties
in Both Cases.
Plaintiffs’ proposals on deposition time already confer a substantial benefit on Google by
ensuring that a Google witness will only be deposed once, on two consecutive days. See
Proposed Order ¶ 4. A Google witness will therefore only have to prepare to be deposed once,
and will not face the challenge of answering questions on the same topic in two separate
depositions separated by months. Third parties will receive the same benefit, plus reductions in
total deposition time depending on how many parties notice the deposition. Id. ¶ 5. Plaintiffs’
proposals otherwise allocate time equally across all parties in both cases, based only on whether
a party has noticed (or cross noticed) a deposition. The Court should adopt plaintiffs’ proposals
because they treat all parties equally.
Google suggests that plaintiffs’ proposals extend Google depositions beyond the
“default” of seven hours, Google Br. 5-6, but Google ignores—only for this one point—that it is
a defendant in two cases, and so is subject to having its personnel deposed on two separate
occasions in the absence of a coordination order. Plaintiffs have asserted their right to litigate in
this forum, and the Court appropriately rejected Google’s request to have this case adjudicated
alongside the MDL. Plaintiffs here should receive a full allotment of time to depose Google
witnesses to ensure the effective prosecution of this enforcement action. In light of the benefits to
Google of its personnel being deposed only once, this is a reasonable outcome. Google should
not receive the added benefit of reduced total deposition time for its current and former
employees.
6
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Case 1:23-cv-00108-LMB-JFA Document 174 Filed 05/04/23 Page 7 of 7 PageID# 1336
CONCLUSION
Plaintiffs respectfully request that the Court adopt their proposals in the Proposed Order,
and otherwise enter the Proposed Order as jointly proposed by plaintiffs and Google.
Dated: May 4, 2023
Respectfully submitted,
JESSICA D. ABER
United States Attorney
JASON S. MIYARES
Attorney General of Virginia
/s/ Gerard Mene
GERARD MENE
Assistant U.S. Attorney
2100 Jamieson Avenue
Alexandria, VA 22314
Telephone: (703) 299-3777
Facsimile: (703) 299-3983
Email: Gerard.Mene@usdoj.gov
/s/ Andrew N. Ferguson
ANDREW N. FERGUSON
Solicitor General
STEVEN G. POPPS
Deputy Attorney General
TYLER T. HENRY
Assistant Attorney General
/s/ Julia Tarver Wood
JULIA TARVER WOOD
/s/ Aaron M. Teitelbaum
AARON M. TEITELBAUM
United States Department of Justice
Antitrust Division
450 Fifth Street NW, Suite 7100
Washington, DC 20530
Telephone: (202) 307-0077
Fax: (202) 616-8544
Email: Julia.Tarver.Wood@usdoj.gov
Attorneys for the United States
Office of the Attorney General of Virginia
202 North Ninth Street
Richmond, VA 23219
Telephone: (804) 692-0485
Facsimile: (804) 786-0122
Email: thenry@oag.state.va.us
Attorneys for the Commonwealth of
Virginia and local counsel for the
States of Arizona, California,
Colorado, Connecticut, Illinois,
Michigan, Minnesota, Nebraska, New
Hampshire, New Jersey, New York,
North Carolina, Rhode Island,
Tennessee, Washington, and West
Virginia
7
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