Public version of Exhibit C-1 — Brooks v. Thomson Reuters Corporation (Dkt. 153.1)

Record facts

U.S. District Court for the Northern District of California · No. 3:21-cv-01418-EMC · Doc. 153-1 · 2023-01-26 · Docket on CourtListener

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EXHIBIT C-1 
 
 
 
Case 3:21-cv-01418-EMC     Document 153-1     Filed 01/26/23     Page 1 of 5

THOMSON REUTERS CLEAR CASE STUDY: 
SAN BERNARDINO MASS SHOOTING 
A Point of Return: How great police work and a database record 
reduced casualties in a mass shooting. 
the answer company^' 
• THOMSON REUTERS® 
CONFIDENTIAL 
TR-BROOKS001855 
Case 3:21-cv-01418-EMC     Document 153-1     Filed 01/26/23     Page 2 of 5

Heroes are not defined by a job description. They neither report for work 
in superhero costumes nor plan their day around superhuman acts. 
They are everyday people who put themselves in harm's way, and help 
support those in harm's way, to respond to life-threatening events 
in a community, such as what happened in San Bernardino, California, 
on December 2, 2015. 
That day, San Bernardino became the center of national attention 
as the site of a mass shooting. They joined in infamy with other cities 
impacted by mass shootings: Charleston, South Carolina; Columbine, 
Colorado; Fort Hood, Texas; and Oak Creek, Wisconsin. Married couple 
Syed Rizwan Farook and Tashfeen Malik fired automatic weapons 
on community members at the Inland Regional Center (IRC) in San 
Bernardino. Fourteen people were killed in the attack and 22 others 
were seriously injured. However, we will never know how many lives 
were saved had the community members, including law enforcement 
personnel, not taken quick action to end the violence. 
CALL TO ACTION 
On that Wednesday morning in December, Sergeant Gary Schuelke of the San Bernardino 
Police Department (SBPD) and his narcotics investigation unit were on surveillance duty 
in Los Angeles when they got word of the mass shooting. Daani Svonkin, then an asset 
forfeiture analyst for the SBPD, while monitoring Schuelke's surveillance, heard a triple-tone 
alert relaying information of an active shooter in the city. 
Earlier that morning, employees of the San Bernardino health department, including Farook 
and a county health inspector, met at the Inland Regional Center for an event. Regional 
Centers are nonprofit private corporations that contract with the California Department 
of Developmental Services to provide services and support to individuals with developmental 
disabilities. Approximately 550 people work at the IRC, which serves the counties of Riverside 
and San Bernardino. 
Farook left the event and returned at 11 a.m. with his wife, Malik, dressed in combat gear 
and carrying assault rifles, and began firing upon health department employees. During 
the attack, a fire alarm was triggered, setting off sprinklers. Workers in nearby buildings 
sheltered in their offices as the carnage ensued. 
Within minutes of SBPD dispatch notifying officers of the IRC incident, law enforcement 
personnel arrived on the scene to engage the active shooter. According to witnesses, 
the suspects had escaped the scene in a black SUV, allowing the police to clear the scene 
and evacuate the injured. During the evacuation, officers discovered an undetonated 
explosive device. 
Once Schuelke received information that multiple people were down at the IRC, he broke 
his team away from surveillance in Los Angeles and started back to the city. When they arrived 
at the scene, there were hundreds of officers at the IRC, and evacuations of the buildings 
were under way and under control. Schuelke directed his team to meet at the command post 
and decided they would focus on locating the suspects. 
Sergeant Gary Schuelke, San Bernardino Police 
Department (SBPD) 
CONFIDENTIAL 
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Case 3:21-cv-01418-EMC     Document 153-1     Filed 01/26/23     Page 3 of 5

According to Svonkin and Schuelke, shortly after the officers arrived at the scene, a witness 
came forward and informed Schuelke's son, also a police officer, that Farook had been 
at the function but left upset and irritated. Farouk became a person of interest for Svonkin, 
who is an expert in finding people and assets from law enforcement and private databases, 
including Thomson Reuters CLEAR records resource. She immediately went to work 
in CLEAR. 
CLEAR brings together key content into a single, easy-to-use interface that provides fast 
and efficient access to a significant amount of public and proprietary records. Typically, 
Svonkin uses CLEAR in her narcotics investigations to locate people, assets, and businesses, 
as well as connecting affiliations and critical facts. She can use the resource to make connections 
between persons of interest to an investigation and other individuals, incidents, activities, 
and locations and generate comprehensive reports. 
Meanwhile, the SBPD received a report of a suspicious vehicle matching the description 
of the vehicle the suspects used to exit the IRC — with a Utah license plate number. Svonkin 
noticed that the plate number was a rental vehicle and reached out to her rental car agency 
contact, who faxed a rental contract back to her that matched the suspect's name. SBPD 
now had confirmed a primary suspect in the shooting. 
Armed with a name, Svonkin returned to CLEAR and located a Redlands address, 
which differed from the address on the rental car contract and the address the suspect 
used on his driver's license and county employment application. That single unique address 
for an apartment in Redlands, however, was within the several-block radius of the ping 
from the suspect's county-owned cell phone, which the police were using in their attempt 
to locate the suspect. Svonkin provided Scheulke and his team with the Redlands address. 
A CLEAR CONNECTION 
Plain-clothes (undercover) police officers first arrived at the Redlands address and witnessed 
a black SUV with Utah plates leaving the location of the apartment. As Schuelke's team 
followed the vehicle, he requested that a marked police unit make an attempt to stop the SUV. 
When the suspect's SUV reached the intersection of San Bernardino Avenue and Tippecanoe 
Avenue, it made a right-hand turn going east on San Bernardino Avenue. Within moments 
of the marked unit lighting up in an attempt to pull the SUV over, gunfire erupted from the SUV, 
which then fully stopped to further engage the officer in the marked unit. With other officers 
assisting, Schuelke and his team pulled over and returned fire. The suspects were killed 
and an officer was injured in the exchange. 
While officers secured and investigated the scene, they discovered a detonating device 
in the SUV. The couple had been driving around the city trying to set off the explosive they left 
at the IRC. Had Svonkin not hastily found the suspect's address in Redlands, the couple may 
have continued their attack, resulting in more civilian and police casualties. 
Svonkin's critical and timely research and the quick action by Schuelke and the SBPD shows 
how CLEAR can be used to quickly identify and locate a person of interest with just one piece 
of information, such as a name, address, or phone number. 
CLEAR links people and businesses to relevant addresses, business names, associates, driver's 
license numbers, phone numbers, Social Security numbers (SSN), and more. In mapping 
addresses to people and businesses, CLEAR makes available underlying source documents, 
such as utility bills and ownership records. Besides its use by law enforcement, CLEAR's 
user interface satisfies multiple use cases, such as conducting corporate due diligence, 
investigating government and health care fraud, and preventing money laundering. 
Danni Svonkin, asset forfeiture analyst, SBPD 
Had Svonkin not hastily found 
the suspect's address in Redlands, 
the couple may have continued 
their attack, resulting in more 
civilian and police casualties. 
CONFIDENTIAL 
TR-BROOKS001857 
Case 3:21-cv-01418-EMC     Document 153-1     Filed 01/26/23     Page 4 of 5

CLEAR's Web user interface allows users to simultaneously search public and proprietary 
databases and the Web. Users can filter out unnecessary data by date range, age, and other 
critical fact distinctions. Entity resolution consolidates and deduplicates search results. 
Like a Google search, the most relevant information to search criteria rises to the top for easy 
review. CLEAR finds results for incomplete information, such as partial birth records, SSN, 
license plates, and street names. 
Content in CLEAR is enhanced in real-time from gateways to current public and proprietary 
data. Information includes consumer and credit bureau data, motor vehicle registration data 
from 45 U.S. states, and phone data (cellular phones, VoIP, landlines, and pagers) in all 50 
states, Puerto Rico, U.S. territories, and Canada. The data includes reverse lookup and Caller 
ID databases, with carrier contact information for subpoena purposes. 
CLEAR comes with add-on subscriptions for law enforcement agencies, which include a 
lineup and bookings database and WorLd-Check®, a data source that compiles FBI, criminal, 
banking sanctions, and other lists. Other add-ons include batch operations, which allow users 
to submit a spreadsheet of criteria for multiple subjects and search across multiple databases 
and facets or metadata. 
CLEAR was built with law enforcement and investigations in mind. With a combination 
of public and proprietary public records and real-time information, customers are confident 
in the results they get while being efficient and cost-effective. Customers, like the San 
Bernardino police department, trust Thomson Reuters CLEAR. 
For more information, visit legalsotutions.com/clear 
Customers, like the San 
Bernardino police department, 
trust Thomson Reuters CLEAR. 
The intelligence, technology and human expertise
::•: ::: 
you need to find trusted answers.
the answer company^ 
THOMSON REUTERS® 
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2016 Thomson Reuter S038407/9-16 
CONFIDENTIAL 
TR-BROOKS001858 
Case 3:21-cv-01418-EMC     Document 153-1     Filed 01/26/23     Page 5 of 5

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