ECLARATION OF ANTHONY P. ALDEN
, Anthony P. Alden, declare as follows:
am an attorney at law duly licensed to practice and of good standing in the State
4 of California, and I am a partner in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP
5 ("the Firm"), counsel of record for Defendants Snapchat, Inc.; Toyopa Group, LLC; Evan Thomas6 Spiegel; and Robert Cornelius Murphy ("Defendants"). I make the statements of fact contained in
7 this declaration on my own personal knowledge, except as to those matters stated upon
8 information and belief, and as to those matters I believe them to be true. If called as a witness in
9 this proceeding, I could and would competently testify to the matters set forth herein.
his declaration is in support of Defendants' Opposition to Plaintiff's Motion to11 Disqualify Quinn Emanuel Urquhart & Sullivan, LLP from representation of Defendants in this12 action ("the Motion").
n preparing this declaration, I have thoroughly reviewed Plaintiff's Motion, the
14 Declaration of Frank Brown ("Brown Decl.") in support thereof, all communications between me15 and Mr. Brown in my possession, and my personal notes and timekeeping records concerning the
16 matter. On the basis of this review and my personal recollection, I dispute the accuracy of many17 of Mr. Brown's allegations concerning the nature and extent of our communications. Contrary to
18 Mr. Brown's assertions, the sum total of my contact with him --- as confirmed by my personal
19 records — was limited to two telephones calls lasting no more than 40 minutes in total, exchanging
20 a waiver agreement, and gathering limited information in order to assess the matter. My records21 confirm that in none of our oral and written communications did I discuss, in detail or otherwise,
22 (a) "the strengths and weakness" or "important and strategic issues" related to potential litigation,23 (b) any "suggestions," (c) give him legal advice, or (d) inform Mr. Brown that I was in the process
24 of discussing the case with my partners at the Firm.
Brown Decl., at 2:17-20, 3:5-6.) Indeed,
25 my time records reflect that I spent no more than 2.1 hours on the matter in total, of which no
26 more than 30 minutes was actually devoted to substantive assessment.
ase No. BC501483
ALDEN DECLARATION ISO DEFENDANTS' OPP'N TO DISQUALIFICATION MOTION