Exhibit 5 to the Mura Declaration - Public Version of ECF No.… — Brooks v. Thomson Reuters Corporation (Dkt. 148.4)

Record facts

U.S. District Court for the Northern District of California · No. 3:21-cv-01418-EMC · Doc. 148-4 · 2022-12-14 · Docket on CourtListener

Full text

EXHIBIT 5
Case 3:21-cv-01418-EMC   Document 148-4   Filed 12/14/22   Page 1 of 9

Confidential - Dori Buckethal
Golkow Litigation Services
Page 1
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     UNITED STATES DISTRICT COURT FOR THE
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       NORTHERN DISTRICT OF CALIFORNIA
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           SAN FRANCISCO DIVISION
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 *  *  *  *  *  *  *  *  *  *  *  *  *  *  *
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CAT BROOKS and RASHEED SHABAZZ, individually
and on behalf of all others similarly situated,
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         Plaintiffs,
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    vs.            Case No.  3:21-cv-1418-EMC
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THOMSON REUTERS CORPORATION,
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         Defendant.
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 *  *  *  *  *  *  *  *  *  *  *  *  *  *  *
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           *****  CONFIDENTIAL *****
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REMOTE VIDEOTAPED DEPOSITION OF DORI BUCKETHAL
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                 May 18, 2022
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            9:00 a.m. to 5:18 p.m.
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         REPORTED BY ANITA KORNBURGER
       REGISTERED PROFESSIONAL REPORTER
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          *****  CONFIDENTIAL  *****
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 *  *  *  *  *  *  *  *  *  *  *  *  *  *  *
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Case 3:21-cv-01418-EMC   Document 148-4   Filed 12/14/22   Page 2 of 9

Confidential - Dori Buckethal
Golkow Litigation Services
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                A P P E A R A N C E S
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GIBBS LAW GROUP LLP, by
Mr. Mark Troutman
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Mr. Ezekiel S. Wald
Mr. Andre Mura
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1111 Broadway, Suite 2100
Oakland, California 94607
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510-350-9700
esw@classlawgroup.com
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Appearing by videoconference on behalf of the
Plaintiffs.
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PERKINS COIE LLP, by
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Ms. Susan Fahringer
Mr. Hayden Schottlaender
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1201 Third Avenue, Suite 4900
Seattle, Washington 98101-3099
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sfahringer@perkinscoie.com
Appearing by videoconference on behalf of the
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Defendant.
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ALSO PRESENT:  Jon Olson - Thomson Reuters
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                      I N D E X
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Examination by                        Page
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Mr. Troutman. . . . . . . . . . . . . . 5
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                   E X H I B I T S
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                                           Page
Exhibit No.  Description                 Identified
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    1        138928. . . . . . . . . . . . . . . 11
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    2        138929. . . . . . . . . . . . . . . 13
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    3        Bates number TR_Brooks 138931. . . .47
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    4        TR_Brooks 8808. . . . . . . . . . . 50
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    5        TR_Brooks129772. . . . . . . . . . .66
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Case 3:21-cv-01418-EMC   Document 148-4   Filed 12/14/22   Page 3 of 9

Confidential - Dori Buckethal
Golkow Litigation Services
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     Q.   And what kinds of interfacing did you
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have with Greg Coyle from the product team?
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     A.   I don't know.  It's a long time ago.  I
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would -- I don't know how I would answer that.
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     Q.   Okay.  You provided here in your resumé
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that right after where the word CLEAR is, it says
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"next generation public records platform."  What
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did you mean by "next generation public records
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platform"?
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     A.   I meant that CLEAR was the next
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generation of a public records platform that
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ChoicePoint previously had called AutoTrack XP.
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     Q.   What was AutoTrack XP?
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     A.   It was an older version of a public
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records platform.
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     Q.   And did CLEAR have improvements on
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AutoTrack XP?
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     A.   Yes.
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     Q.   What types of improvements?
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     A.   From what I remember, I would say the
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interface, you know, the user interface, the way it
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looks.  I'm certain there were other technology
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upgrades, but I'm not -- that's not my area of
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expertise, so I wouldn't -- I wouldn't be able to
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state those.  I wouldn't remember.
Case 3:21-cv-01418-EMC   Document 148-4   Filed 12/14/22   Page 4 of 9

Confidential - Dori Buckethal
Golkow Litigation Services
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     A.   Yes.
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     Q.   And what I'm trying to get at is how is
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CLEAR different today than it was in 2008 when it
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first launched?
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     A.   Oh, gosh.  I don't know.  I don't think I
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could answer that question.  It seems very -- very
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general.
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     Q.   What kind of features have been added
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between 2008 and today to CLEAR?
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     A.   I could -- I could guess at a few things.
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I don't know if I could come up with a full list
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here.
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     Q.   Okay.  I don't want you to guess.  Just a
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couple examples.  I understand that, you know, a
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full list off the top of your head might be
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difficult.
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     A.   Okay.  So 2008 to now, what kind of
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features.  I know that different versions of the
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product have probably been enhanced or launched in
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that time period, so those would be features that
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were new.  One that comes to mind is CLEAR ID
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Confirm would be something new between 2008 and
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now.
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     Q.   Okay.  When you said different versions,
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what would be different from one version to
Case 3:21-cv-01418-EMC   Document 148-4   Filed 12/14/22   Page 5 of 9

Confidential - Dori Buckethal
Golkow Litigation Services
Page 60
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in California?
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          MS. FAHRINGER:  Form.
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          THE WITNESS:  Would I agree that CLEAR
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contains data concerning individuals that reside in
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California.  Yes.
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BY MR. TROUTMAN:
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     Q.   Do you know when CLEAR first began
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selling data from individuals residing in
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California?
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          MS. FAHRINGER:  Form.
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          THE WITNESS:  No, I don't know that.
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BY MR. TROUTMAN:
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     Q.   Does CLEAR contain data on individuals'
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residency?
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          MS. FAHRINGER:  Form.
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          THE WITNESS:  What do you mean by
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"residency"?
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BY MR. TROUTMAN:
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     Q.   Where someone lives.
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     A.   I would say that CLEAR contains address
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information.
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     Q.   Do you currently use any form of digital
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advertising to advertise for CLEAR?
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     A.   What do you mean by "digital
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advertising"?
Case 3:21-cv-01418-EMC   Document 148-4   Filed 12/14/22   Page 6 of 9

Confidential - Dori Buckethal
Golkow Litigation Services
Page 264
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CERTIFICATE
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   I, Anita Kornburger, Registered Professional
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    Reporter and Certified Shorthand Reporter, do
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    hereby certify that prior to the commencement
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    of the deposition, Dori Buckethal was duly
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    remotely sworn by me to testify to the truth,
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    the whole truth and nothing but the truth.
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I DO FURTHER CERTIFY that the foregoing is
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    a verbatim transcript of the testimony as taken
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    stenographically by me at the time, place and
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    on the date set forth, to the best of my
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    ability.
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I DO FURTHER CERTIFY that I am neither
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    a relative nor employee nor attorney nor
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    counsel of any of the parties to this action,
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    and that I am neither a relative nor employee
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    of such attorney or counsel, and that I am not
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    financially interested in the action.
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     ____________________________
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  Anita Kornburger
  Registered Professional Reporter
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  Certified Shorthand Reporter
  Notary Public
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  Dated: May 23, 2022
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Case 3:21-cv-01418-EMC   Document 148-4   Filed 12/14/22   Page 7 of 9

 
June 23, 2022 
 
 
 
Re:  Brooks et al. v. Thomson Reuters Corporation,  
USDC Northern District of California - San Francisco Division 
Case No. 3:21-cv-01418-EMC 
 
Deposition Errata for the Deposition of Dorian Buckethal 
(Transcript dated May 18, 2022) 
 
 
To whom it may concern: 
 
I, Dorian Buckethal, have reviewed the transcript of my deposition in Brooks 
et al. v. Thomson Reuters Corporation, Case No. 3:21-cv-01418-EMC, taken on May 
18, 2022.  Attached hereto is a list of errata identified in the deposition transcript. 
 
 
 
 
 
/s/ Dorian Buckethal 
 
 
 
 
June 23, 2022_____________ 
DORIAN BUCKETHAL  
 
 
 
DATE 
 
 
 
 
 
Case 3:21-cv-01418-EMC   Document 148-4   Filed 12/14/22   Page 8 of 9

 
 
 
Dorian Buckethal Deposition Errata Sheet 
  
Page:Line(s) 
Existing 
Testimony 
Corrected 
Testimony 
Reason 
14:12 
“job that he was 
passing my e-mail -
- my resumé…” 
“job that he was 
passing my resumé”  
Misstatement  
22:10 
“account manager” 
“account managers” 
Transcription error 
28:22 
“Steve Brubely” 
“Steve Rubely” 
Transcription error 
30:17 
“I don’t -- I don’t 
recall” 
“I don’t recall” 
Misstatement 
35:3 
“marketing man” 
“marketing 
manager” 
Transcription error 
37:3-4 
“product into the 
corp -- our 
corporate…” 
“product into our 
corporate…” 
Misstatement 
42:9 
“Buquette Bysett” 
“Buket Bayaset” 
Transcription error 
45:5 
“market” 
“marketing” 
Transcription error 
171:20-22 
“I don’t know how to 
answer that 
question. I don’t 
know how to 
answer that 
question.” 
“I don’t know how to 
answer that 
question.” 
Transcription error 
182:8 
“reasonable, but 
that’s…” 
“reasonable, 
that’s…” 
Transcription error 
247:1 
“The every major…” 
“That every 
major…” 
Transcription error 
 
 
 
Case 3:21-cv-01418-EMC   Document 148-4   Filed 12/14/22   Page 9 of 9

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