Public version of Exhibit A-16 — Brooks v. Thomson Reuters Corporation (Dkt. 151.16)

Record facts

U.S. District Court for the Northern District of California · No. 3:21-cv-01418-EMC · Doc. 151-16 · 2023-01-26 · Docket on CourtListener

Full text

EXHIBIT A-16 
 
 
 
Case 3:21-cv-01418-EMC     Document 151-16     Filed 01/26/23     Page 1 of 11

8/22/2022
Cat Brooks and Rasheed Shabazz, et al. v. Thomson Reuters Corp.
Terry Lloyd
www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2022
202-232-0646
Page 1
              UNITED STATES DISTRICT COURT
            NORTHERN DISTRICT OF CALIFORNIA
                 SAN FRANCISCO DIVISION
______________________________
CAT BROOKS and RASHEED        )
SHABAZZ, individually and on  )
behalf of all others          )
similarly situation,          )
                              )
     Plaintiffs,              ) Civil No.
                              ) 3:21-cv-01418-EMC
  v.                          )
                              )
THOMSON REUTERS               )
CORPORATION,                  )
                              ) Hon. Edward M. Chen
     Defendant.               )
______________________________)
               DEPOSITION OF TERRY LLOYD
               August 22, 2022  9:18 a.m.
        Location: DEPOSITION BY VIDEOCONFERENCE
Reported by:
HEIDI HUNTER, RPR, CSR
______________________________________________________
                  DIGITAL EVIDENCE GROUP
              1730 M Street, NW, Suite 812
                  Washington, D.C. 20036
                     (202) 232-0646   
Case 3:21-cv-01418-EMC     Document 151-16     Filed 01/26/23     Page 2 of 11

8/22/2022
Cat Brooks and Rasheed Shabazz, et al. v. Thomson Reuters Corp.
Terry Lloyd
www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2022
202-232-0646
Page 2
1
                 A P P E A R A N C E S
2
FOR THE PLAINTIFF:
3
          Amy Zeman
4
          Andre M. Mura
5
          Ezekiel S. Wald
6
          GIBBS LAW GROUP
7
          Attorneys at Law
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          505 14th Street, Suite 1110
9
          Oakland, CA 94612
10
          Email: amz@classlawgroup.com
11
12
FOR THE DEFENDANT:
13
          Hayden M. Schottlaender
14
          Susan D. Fahringer
15
          Kayla Lindgren
16
          PERKINS COIE, LLP
17
          Attorneys at Law
          500 N Akard Street, Suite 3300
18
          Dallas, TX 75201
          Email: hschottlaender@perkinscoie.com
19
20
21
22
Case 3:21-cv-01418-EMC     Document 151-16     Filed 01/26/23     Page 3 of 11

8/22/2022
Cat Brooks and Rasheed Shabazz, et al. v. Thomson Reuters Corp.
Terry Lloyd
www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2022
202-232-0646
Page 101
1
for California natural persons.
2
     Q    If we go to page 18 of your report.  This
3
table contains the same calculations as in the
4
Exhibit 1 table we just looked at, but does not
5
contain the blanks for other information that might be
6
missing; is that right?
7
     A    I think that's a fair summary.
8
     Q    And in the calculations that you have
9
performed with the numbers that you do have both on
10
page 18 and in Exhibit 1, is there any accounting here
11
for just portions of CLEAR or unjust portions of
12
CLEAR?
13
     A    My answer is the same as when you asked me
14
that previously.  I was not asked to do that.  I am
15
not a lawyer.  It is not a question that I addressed.
16
          MS. ZEMAN:  We've been going for, I think,
17
quite a bit over an hour.  Can we take a 10-minute
18
break.
19
          MR. SCHOTTLAENDER:  We're about to go in
20
to -- we can do like a longer lunch break in about 20
21
minutes.
22
          Do you want to do that?
8
Q 
And in the calculations that you have
9
performed with the numbers that you do have both on
10
page 18 and in Exhibit 1, is there any accounting here
11
for just portions of CLEAR or unjust portions of
12
CLEAR?
13
A 
My answer is the same as when you asked me
14
that previously. I was not asked to do that. I am
15
not a lawyer. It is not a question that I addressed.
Case 3:21-cv-01418-EMC     Document 151-16     Filed 01/26/23     Page 4 of 11

8/22/2022
Cat Brooks and Rasheed Shabazz, et al. v. Thomson Reuters Corp.
Terry Lloyd
www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2022
202-232-0646
Page 287
1
2
REPORTER'S CERTIFICATE
3
STATE OF UTAH        )
4
COUNTY OF SALT LAKE  )
5
6
I, Heidi Hunter, RPR, CCR, for the state
7
of Utah.
8
That the foregoing proceedings were taken
before me at the time and place set forth in the
9
caption hereof; that the witness was placed under
oath to tell the truth, the whole truth, and nothing
10
but the truth.
That I thereafter transcribed my said
11
shorthand notes into typing and that the typewritten
transcript of said deposition is a complete, true
12
and accurate transcription of my said shorthand
notes taken at said time.
13
I further certify that I am not a relative
employee, attorney, or counsel of any of the parties
14
nor am I a relative or employee of any of the
parties' attorney or counsel connected with the
15
action, nor am I financially interested in the
action.
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17
18
19
20
________________________________
21
Heidi Hunter, RPR, CCR
22
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