Court filing
EXHIBITS re 150 Administrative Motion to File Under Seal… — Brooks v. Thomson Reuters Corporation (Dkt. 151)
Summary
A Declaration of Susan D. Fahringer in Support of Defendant Thomson Reuters Corporation's Class Certification Opposition, Document 151, filed 01/26/23 in Case 3:21-cv-01418-EMC, Cat Brooks and Rasheed Shabazz v. Thomson Reuters Corporation, in the United States District Court for the Northern District of California, San Francisco Division, three pages, before Hon. Edward M. Chen. The declarant states that she is a partner with Perkins Coie and one of the attorneys for Defendant. She attaches as Exhibit A-1 the Expert Report of Professor Jane Bambauer served on September 7, 2022, as Exhibit A-2 excerpts of the deposition of Plaintiff Cat Brooks taken on August 10, 2022 and as Exhibit A-3 excerpts of the deposition of Plaintiff Rasheed Shabazz taken on August 18, 2022.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“EXHIBITS re 150 Administrative Motion to File Under Seal… — Brooks v. Thomson Reuters Corporation (Dkt. 151).”
Original at ecf.cand.uscourts.gov, No. 3:21-cv-01418-EMC, Doc. 151. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-brooks-thomsonreuters-cand-374304/2023-01-26-gov-uscourts-cand-374304-151-0-gov-uscourts-cand-374304-151-0/
, SHA-256 8d58e6cfefd5809567c3f7259416af30a6d97259e997d8eea2a25850493e45d5.Full text
Case 3:21-cv-01418-EMC Document 151 Filed 01/26/23 Page 1 of 3
1 Susan D. Fahringer, Bar No. 21567 Gabriella Gallego, Bar No. 324226
SFahringer@perkinscoie.com GGallego@perkinscoie.com
2 Nicola C. Menaldo, pro hac vice PERKINS COIE LLP
3 NMenaldo@perkinscoie.com 3150 Porter Drive
Erin K. Earl, pro hac vice Palo Alto, CA 94304-1212
4 EEarl@perkinscoie.com Telephone: 650.838.4300
Anna M. Thompson, pro hac vice Facsimile: 650.838.4350
5 AnnaThompson@perkinscoie.com
PERKINS COIE LLP Hayden M. Schottlaender, pro hac vice
6
1201 Third Avenue, Suite 4900 HSchottlaender@perkinscoie.com
7 Seattle, WA 98101-3099 PERKINS COIE LLP
Telephone: 206.359.8000 500 N. Akard Street, Suite 3300
8 Facsimile: 206.359.9000 Dallas, TX 75201-3347
Attorneys for Defendant Telephone: 214.965.7700
9 Thomson Reuters Corporation Facsimile: 214.965.7799
10
11
UNITED STATES DISTRICT COURT
12
NORTHERN DISTRICT OF CALIFORNIA
13
SAN FRANCISCO DIVISION
14
15
CAT BROOKS and RASHEED SHABAZZ, Case No. 3:21-cv-01418-EMC
16
individually and on behalf of all others
17 similarly situated, DECLARATION OF SUSAN D.
FAHRINGER IN SUPPORT OF
18 Plaintiff, DEFENDANT THOMSON REUTERS
CORPORATION’S CLASS
19 v. CERTIFICATION OPPOSITION
20 THOMSON REUTERS CORPORATION, Hon. Edward M. Chen
21 Defendants.
22
23
24
25
26
EXHIBIT
27
A
28
NO. 3:21-CV-01418-EMC DECLARATION OF SUSAN D. FAHRINGER
Case 3:21-cv-01418-EMC Document 151 Filed 01/26/23 Page 2 of 3
1 I, Susan D. Fahringer, declare as follows:
2 1. I am a partner with Perkins Coie LLC and am one of the attorneys for Defendant
3 Thomson Reuters Corporation (“Thomson Reuters”) in this case. I make this Declaration based
4 on my personal knowledge and am competent to testify to its contents.
5 2. Attached as Exhibit A-1 is a true and correct copy of the Expert Report of
6 Professor Jane Bambauer, served on Plaintiffs by Thomson Reuters on September 7, 2022.
7 3. Attached as Exhibit A-2 is a true and correct copy of excerpts from transcript of
8 the deposition of Plaintiff Cat Brooks, taken on August 10, 2022.
9 4. Attached as Exhibit A-3 is a true and correct copy of excerpts from the transcript
10 of the deposition of Plaintiff Rasheed Shabazz, taken on August 18, 2022.
11 5. Attached as Exhibit A-4 is a true and correct screen capture of the “Bio” page of
12 catbrooks.org, located at URL https://www.catbrooks.org/bio, which was captured at my direction
13 on January 20, 2023.
14 6. Attached as Exhibit A-5 is a true and correct screen capture of the landing page of
15 catbrooks.org, located at URL https://www.catbrooks.org, which was captured at my direction on
16 January 20, 2023.
17 7. Attached as Exhibit A-6 is a true and correct screen capture of the Wikipedia page
18 for “Cat Brooks,” located at URL https://en.wikipedia.org/wiki/Cat_Brooks, which was captured
19 at my direction on November 29, 2021 and was marked and used as Exhibit 5 at the Deposition of
20 Plaintiff Cat Brooks, taken on August 10, 2022.
21 8. Attached as Exhibit A-7 is a true and correct screen capture of the IMDb page for
22 “Cat Brooks,” located at URL https://www.imdb.com/name/nm9644547/, which was captured at
23 my direction on January 17, 2023.
24 9. Attached as Exhibit A-8 is a true and correct screen capture of the “Press” page of
25 catbrooks.org, located at URL https://www.catbrooks.org/presss, which was captured at my
26 direction on July 11, 2022 and was marked and used as Exhibit 4 at the Deposition of Plaintiff
27 Cat Brooks, taken on August 10, 2022.
28 10. Attached as Exhibit A-9 is a true and correct copy of a document produced in this
NO. 3:21-CV-01418-EMC -1- DECLARATION OF SUSAN D. FAHRINGER
Case 3:21-cv-01418-EMC Document 151 Filed 01/26/23 Page 3 of 3
1 litigation by Plaintiffs bearing Bates No. PLAINTIFFS_005653 - PLAINTIFFS_005661.
2 11. Attached as Exhibit A-10 is a true and correct copy of a document produced in
3 this litigation by Plaintiffs bearing Bates No. PLAINTIFFS_005538 - PLAINTIFFS_005547.
4 12. Attached as Exhibit A-11 is a true and correct copy of a document produced in
5 this litigation by Plaintiffs bearing Bates No. PLAINTIFFS_011126 - PLAINTIFFS_011253.
6 13. Attached as Exhibit A-12 is a true and correct copy of a document produced in
7 this litigation by Plaintiffs bearing Bates No. PLAINTIFFS_011275 - PLAINTIFFS_011312.
8 14. Attached as Exhibit A-13 is a true and correct copy of excerpts from the transcript
9 of the deposition of Joseph Turow, Ph.D., taken on August 26, 2022.
10 15. Attached as Exhibit A-14 is a true and correct copy of the Expert Report of Dr.
11 Ran Kivetz, served by Thomson Reuters on Plaintiffs on September 7, 2022.
12 16. Attached as Exhibit A-15 is a true and correct copy of excerpts from the transcript
13 of the hearing held before this Court in this case on June 30, 2022 regarding Non-Party File &
14 ServeXpress, LLC’s Motion for Limited Intervention and for Protective Order.
15 17. Attached as Exhibit A-16 is a true and correct copy of excerpts from the transcript
16 of the deposition of Terry Lloyd, taken on August 22, 2022.
17 18. Attached as Exhibit A-17 is a true and correct copy of the Expert Report of
18 Douglas Kidder, served by Thomson Reuters on Plaintiffs on September 7, 2022.
19
20 I declare under penalty of perjury that the foregoing is true and correct.
21 Executed January 26, 2023, in Seattle, Washington.
22
By: s/ Susan D. Fahringer
23 Susan D. Fahringer, Bar No. 21567
SFahringer@perkinscoie.com
24
Attorney for Defendants
25 Thomson Reuters Corporation
26
27
28
NO. 3:21-CV-01418-EMC -2- DECLARATION OF SUSAN D. FAHRINGER
File and source
- File
- gov.uscourts.cand.374304.151.0.pdf
- Size
- 137,555 bytes
- SHA-256
- 8d58e6cfefd5809567c3f7259416af30a6d97259e997d8eea2a25850493e45d5
- Original
- PACER (login required)