Declaration of Andre M. Mura — Brooks v. Thomson Reuters Corporation (Dkt. 158.1)

Summary

Document 158-1, filed 02/06/23 in Case 3:21-cv-01418-EMC-KAW (Brooks v. Thomson Reuters Corporation, N.D. Cal.), is a Declaration of Andre M. Mura, a partner at Gibbs Law Group LLP, in support of Plaintiffs' Administrative Motion to Consider Whether Another Party's Material Should Be Sealed. Under Local Rule 79-5(f), he states that portions of an exhibit to his declaration supporting Plaintiffs' Omnibus Motion to Exclude Expert Opinions on Class Certification were designated CONFIDENTIAL or HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY by Defendant under the Stipulated Protective Order (ECF No. 70). He then lists portions of Plaintiffs' motion that quote or refer to those exhibits or to expert reports submitted under seal by Defendant. The signature line reads Executed on February 6, 2022, in Oakland, California.

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

Full text

          Case 3:21-cv-01418-EMC          Document 158-1    Filed 02/06/23   Page 1 of 3




 1    Eric H. Gibbs (SBN 178658)                        Geoffrey A. Graber (SBN 211547)
      Andre M. Mura (SBN 298541)                        Karina G. Puttieva (SBN 317702)
 2
      Amy M. Zeman (SBN 273100)                         COHEN MILSTEIN SELLERS & TOLL
 3    Mark H. Troutman (pro hac vice)                   PLLC
      Ezekiel S. Wald (SBN 341490)                      1100 New York Ave. NW, Fifth Floor
 4                                                      Washington, DC 20005
      Hanne Jensen (SBN 336045)
 5    GIBBS LAW GROUP LLP                               Telephone: (202) 408-4600
      1111 Broadway, Suite 2100                         Facsimile: (202) 408-4699
 6    Oakland, CA 94607                                 ggraber@cohenmilstein.com
 7    Telephone: (510) 350-9700                         kputtieva@cohenmilstein.com
      Facsimile: (510) 350-9701
 8    ehg@classlawgroup.com
 9    amm@classlawgroup.com
      amz@classlawgroup.com
10    mht@classlawgroup.com
11    zsw@classlawgroup.com
      hj@classlawgroup.com
12
13   Attorneys for Plaintiffs and the Proposed Class

14
15
                           UNITED STATES DISTRICT COURT FOR THE
16                           NORTHERN DISTRICT OF CALIFORNIA
17                               SAN FRANCISCO DIVISION

18   CAT BROOKS and RASHEED SHABAZZ,                   Case No. 3:21-cv-01418-EMC-KAW
     individually and on behalf of all others
19
     similarly situated,                               DECLARATION OF ANDRE M. MURA IN
20                                                     SUPPORT OF PLAINTIFFS’
                    Plaintiffs,                        ADMINISTRATIVE MOTION TO
21
            v.                                         CONSIDER WHETHER ANOTHER
22                                                     PARTY’S MATERIALS SHOULD BE
     THOMSON REUTERS CORPORATION,                      SEALED
23
24                  Defendant.                         Hon. Edward M. Chen

25
26
27
28
            DECLARATION OF ANDRE M. MURA IN SUPPORT OF PLAINTIFFS’
          ADMINISTRATIVE MOTION TO CONSIDER WHETHER ANOTHER PARTY’S
                          MATERIALS SHOULD BE SEALED
                          Case No. 3:21-cv-01418-EMC-KAW
          Case 3:21-cv-01418-EMC         Document 158-1       Filed 02/06/23    Page 2 of 3




 1          I, Andre M. Mura, declare under penalty of perjury:
 2          1.      I am a member in good standing of the Bar of California and the bar of this
 3   Court. I am a partner at Gibbs Law Group LLP in Oakland, California, and represent
 4   Plaintiffs in this matter.
 5          2.      I have personal knowledge of the facts set forth herein and, if called as a
 6   witness, could and would testify competently to them.
 7          3.      I submit this declaration in support of Plaintiffs’ Administrative Motion to
 8   Consider Whether Another Party’s Material Should Be Sealed.
 9          4.      Pursuant to Local Rule 79-5(f), I hereby state that the following documents,
10   which are exhibits to the Declaration of Andre M. Mura in Support of Plaintiffs’ Omnibus
11   Motion to Exclude Expert Opinions on Class Certification (“Motion”), have been
12   designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
13   ONLY” by Defendant under the operative Stipulated Protective Order in this action. See
14   ECF No. 70:
15
                 Exhibit to Mura          Portion Designated as “CONFIDENTIAL” or
16           Declaration in Support of    “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
                Plaintiffs’ Motion        ONLY” by Defendant
17
                       Ex. 1              26:19-27:2; 27:16-28:5; 40:5-40:23; 41:18-41:20
18
19          5.      The following portions of Plaintiffs’ Omnibus Motion to Exclude Expert
20   Opinions on Class Certification quote from or otherwise refer to the exhibits referenced in
21   Paragraph 4 above and so may also be potentially considered confidential by Defendant:
22                                        Portion of Plaintiffs’ Motion
23           Page 9, line 27 (between “generating” and “of”)
24
25          6.      The following portions of Plaintiffs’ Motion to Exclude quote from or
26   otherwise refer to expert reports that were submitted under seal by Defendant and so may
27   also be potentially considered confidential by Defendant:
28
                                           1
            DECLARATION OF ANDRE M. MURA IN SUPPORT OF PLAINTIFFS’
          ADMINISTRATIVE MOTION TO CONSIDER WHETHER ANOTHER PARTY’S
                          MATERIALS SHOULD BE SEALED
                          Case No. 3:21-cv-01418-EMC-KAW
         Case 3:21-cv-01418-EMC        Document 158-1       Filed 02/06/23    Page 3 of 3




 1                                Provisionally Sealed Portion of Motion
 2          Page 3, lines 9-10 (between “here” and end of sentence)
            Page 3, lines 11-12 (between “harms” and end of sentence)
 3
            Page 3, lines 12-14 (between “that” and end of sentence)
 4          Page 3, lines 14-15 (between “fourth,” and end of sentence)
 5          Page 4, lines 1-2 (between “that” and end of sentence)
            Page 4, lines 4-5 (from start of line to end of sentence)
 6          Page 4, line 5 (between “of” and “is”)
 7          Page 4, lines 21-22 (between “case” and end of sentence)
            Page 5, line 8 (between “Kivetz’s” and end of line)
 8          Page 6, line 13 (between “mischaracterizes as a” and “only”)
 9          Page 6, line 13 (between “necessitates” and end of sentence)
            Page 6, lines 14-16 (between “show that” to end of sentence)
10          Page 6, lines 18-20 (between “why” to “or know”)
11          Page 7, line 16 (between “consumers’” and “when Californians”)
            Page 8, line 19 (from beginning of line to “with the implication”)
12          Page 8, lines 25-26 (between “marketplace,” to “ECF No. 151-14”)
13          Page 8, line 27 (from beginning of line to end of sentence)
            Page 9, lines 4-6 (from “speculate that” to end of sentence)
14          Page 10, line 11 (between “survey by” and “—without”)
15          Page 10, lines 14-15 (between “questions such as” and “without offering”)
            Page 10, lines 22.5-23.5 (from “arguing that because” to end of sentence)
16
            Page 11, lines 12-13 (between “Turow” to “and that”)
17          Page 11, line 13 (between “position is” and “and”)
            Page 11, line 13 (from “and” to end of sentence)
18
            Page 14, lines 4-6 (quotation in parenthetical)
19
20         I declare that the foregoing is true and correct. Executed on February 6, 2022, in
21   Oakland, California.
22
23                                                   /s/ Andre M. Mura
                                                     Andre M. Mura
24
25
26
27
28
                                           2
            DECLARATION OF ANDRE M. MURA IN SUPPORT OF PLAINTIFFS’
          ADMINISTRATIVE MOTION TO CONSIDER WHETHER ANOTHER PARTY’S
                          MATERIALS SHOULD BE SEALED
                          Case No. 3:21-cv-01418-EMC-KAW


File and source

File

gov.uscourts.cand.374304.158.1.pdf

Size

235,922 bytes

SHA-256

84d143396a350b0062d9921ae549ce95e22e1ed359012556e2d594bea06af556

Our copy

gov.uscourts.cand.374304.158.1.pdf

Original

PACER (login required)