`
`CARELLA, BYRNE, CECCHI, OLSTEIN, BRODY & AGNELLO, P.C.
`COUNSELLORS AT LAW
`
`CHARLES C. CARELLA
`JAN ALAN BRODY
`JOHN M. AGNELLO
`CHARLES M. CARELLA
`JAMES E. CECCHI
`
`
`
`
`
`DONALD F. MICELI
`CARL R. WOODWARD, III
`MELISSA E. FLAX
`DAVID G. GILFILLAN
`G. GLENNON TROUBLEFIELD
`BRIAN H. FENLON
`CAROLINE F. BARTLETT
`ZACHARY S. BOWER+
`DONALD A. ECKLUND
`CHRISTOPHER H. WESTRICK*
`STEPHEN R. DANEK
`MICHAEL A. INNES
`MEGAN A. NATALE
`KEVIN G. COOPER
`
`_____________
`
`5 BECKER FARM ROAD
`ROSELAND, N.J. 07068-
`1739
`PHONE (973) 994-1700
`FAX (973) 994-1744
`www.carellabyrne.com
`
`October 10, 2024
`
`VIA ECF
`Hon. Julien Xavier Neals, U.S.D.J.
`Martin Luther King Bldg. & U.S. Courthouse
`50 Walnut Street
`Newark, New Jersey 07102
`
`RAYMOND J. LILLIE
`GREGORY G. MAROTTA
`MARYSSA P. GEIST
`JORDAN M. STEELE**
`SEAN M. KILEY
`ROBERT J. VASQUEZ
`BRITTNEY M. MASTRANGELO
`GRANT Y. LEE***
`
` PETER G. STEWART
` FRANCIS C. HAND
` JAMES A. O’BRIEN, III
` JOHN G. ESMERADO
` STEVEN G. TYSON
` MATTHEW J. CERES
` ZACHARY A. JACOBS***
` JASON H. ALPERSTEIN+ +
`
`OF COUNSEL
`
`*CERTIFIED BY THE SUPREME COURT OF
`NEW JERSEY AS A CIVIL TRIAL ATTORNEY
`**MEMBER NY BAR
`***MEMBER IL BAR
`+MEMBER FL BAR
`+ + MEMBER NY & FL BAR
`
`Re:
`
`In re: Apple Inc. Smartphone Antitrust Litigation,
`Civil Action No. 2:24-md-03113
`
`Dear Judge Neals:
`
`I represent plaintiffs in the Direct Purchaser class in the above-referenced matter and am
`part of the Majority Group’s proposed leadership structure. We write in response to the Court’s
`Text Order dated October 9, 2024, directing plaintiffs to outline the organizational and other
`preliminary issues that can be addressed on November 6, 2024, or another convenient time.
`
`Plaintiffs believe it would be beneficial to discuss the pending motions to appoint lead
`counsel under Rule 23(g). Resolving this issue will enable the private plaintiffs to begin drafting
`an amended complaint and initiate early case management activities such as negotiating a
`Protective Order, ESI Protocol, and Source Code Protocol. Additionally, in response to Your
`Honor’s Text Order this morning, I will advise the Court by October 25 of the number of
`anticipated attendees at the tutorial. We appreciate the Court’s consideration of these issues and
`look forward to discussing them further on November 6, 2024, or at a subsequent hearing as
`deemed appropriate by the Court.
`
`Respectfully submitted,
`
`CARELLA BYRNE CECCHI
`BRODY & AGNELLO, P.C.
`
`/s/ James E. Cecchi
`JAMES E. CECCHI
`
`cc: Hon. Leda Dunn Wettre, U.S.M.J.
`Counsel of Record
`
`
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