Court filing
Exhibit 1 — Brooks v. Thomson Reuters Corporation (Dkt. 166.3)
Filed March 6, 2023 in Brooks v. Thomson Reuters Corporation; one of 127 filings from this case.
Record facts
| Court | U.S. District Court for the Northern District of California |
|---|---|
| Filed | 2023-03-06 |
U.S. District Court for the Northern District of California · No. 3:21-cv-01418-EMC · Doc. 166-3 · 2023-03-06 · Docket on CourtListener
Full text
EXHIBIT 1
Case 3:21-cv-01418-EMC Document 166-3 Filed 03/06/23 Page 1 of 7
8/26/2022
Cat Brooks and Rasheed Shabazz, et al. v. Thomson Reuters Corp.
Joseph Turow, Ph.D.
Confidential
www.DigitalEvidenceGroup.com
Digital 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 situated, )
) Case No.
Plaintiffs, ) 3:21-cv-01418-EMC
)
-vs- )
)
THOMSON REUTERS )
CORPORATION, )
)
Defendant. )
___________________________)
****CONFIDENTIAL****
VIDEOTAPED DEPOSITION
TAKEN REMOTELY VIA VIDEOCONFERENCE
OF
JOSEPH TUROW, PH.D.
AUGUST 26, 2022
11:03 A.M.
REPORTED BY:
DEBRA SAPIO LYONS, RDR, CRR, CRC, CCR, CLR, CPE
______________________________________________________
DIGITAL EVIDENCE GROUP
1730 M Street, NW, Suite 812
Washington, D.C. 20036
(202) 232-0646
Case 3:21-cv-01418-EMC Document 166-3 Filed 03/06/23 Page 2 of 7
8/26/2022
Cat Brooks and Rasheed Shabazz, et al. v. Thomson Reuters Corp.
Joseph Turow, Ph.D.
Confidential
www.DigitalEvidenceGroup.com
Digital Evidence Group C'rt 2022
202-232-0646
Page 2
1
August 26, 2022
2
Videotaped deposition, taken remotely via
3
videoconference, of Joseph Turow, Ph.D., reported
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remotely via Zoom Videoconference by Debra Sapio
5
Lyons, a Registered Diplomat Reporter, a Certified
6
Realtime Reporter, a Certified Realtime Captioner,
7
a Certified LiveNote Reporter, an Approved Reporter
8
of the United States District Court for the Eastern
9
District of Pennsylvania, a Certified Court
10
Reporter of the State of New Jersey, a Notary
11
Public of the States of New Jersey, Delaware and
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the Commonwealth of Pennsylvania.
13
14
15
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Case 3:21-cv-01418-EMC Document 166-3 Filed 03/06/23 Page 3 of 7
8/26/2022
Cat Brooks and Rasheed Shabazz, et al. v. Thomson Reuters Corp.
Joseph Turow, Ph.D.
Confidential
www.DigitalEvidenceGroup.com
Digital Evidence Group C'rt 2022
202-232-0646
Page 3
1
(All Counsel and Participants present via Zoom
2
videoconference.)
3
APPEARANCES:
GIBBS LAW GROUP LLP
4
BY: AMY ZEMAN, ESQUIRE
EZEKIEL WALD, ESQUIRE
5
ANDRE MURA, ESQUIRE
1111 Broadway - Suite 2100
6
Oakland, California 94607
510.350.9721
7
amz@classlawgroup.com
510.340.4285
8
zsw@classlawgroup.com
510.350.9717
9
amm@classlawgroup.com
10
Attorneys for Plaintiffs
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PERKINS COIE LLP
BY: SUSAN FAHRINGER, ESQUIRE
13
1201 Third Avenue - Suite 4900
Seattle, Washington 98101-3099
14
206.359.8687
SFahringer@perkinscoie.com
15
AND
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PERKINS COIE LLP
BY: HAYDEN SCHOTTLAENDER, ESQUIRE
17
500 North Akard Street - Suite 3300
Dallas, Texas 75201-3347
18
214.965.7724
HSchottlaender@perkinscoie.com
19
Attorneys for Defendant
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ALSO PRESENT:
HENRY MARTE, VIDEOGRAPHER/DOCUMENT TECH
22
DIGITAL EVIDENCE GROUP
Case 3:21-cv-01418-EMC Document 166-3 Filed 03/06/23 Page 4 of 7
8/26/2022
Cat Brooks and Rasheed Shabazz, et al. v. Thomson Reuters Corp.
Joseph Turow, Ph.D.
Confidential
www.DigitalEvidenceGroup.com
Digital Evidence Group C'rt 2022
202-232-0646
Page 151
1
control their information and as consequence it
2
is -- it is harming their privacy rights. Whether
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there is some individual somewhere who might say
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that, in your hypothetical world, that a particular
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type of data is okay, is something that is a
6
question and I would frankly doubt that there are
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people out there. But that's not what I'm asked to
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opine about.
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Q. That's fine. I want to just make sure
10
I've got the scope of your testimony in this case.
11
And just for clarity, I'm going to ask the question
12
again.
13
Is it your testimony in this case that
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every person in California would object to their
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information being in CLEAR?
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MS. ZEMAN: Objection, asked and
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answered.
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THE WITNESS: And I'm -- I'm saying
19
that that's not what I asked -- that's not
20
what I'm asked to be -- opine about.
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BY MS. FAHRINGER:
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Q. Okay. So that's not your opinion in
Case 3:21-cv-01418-EMC Document 166-3 Filed 03/06/23 Page 5 of 7
8/26/2022
Cat Brooks and Rasheed Shabazz, et al. v. Thomson Reuters Corp.
Joseph Turow, Ph.D.
Confidential
www.DigitalEvidenceGroup.com
Digital Evidence Group C'rt 2022
202-232-0646
Page 152
1
this case; correct?
2
A. It's not what I've written about.
3
Q. And your opinion is reflected in your
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in your opinion that is --
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A. The larger point is it's not what --
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that point does not affect my conclusion.
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Q. Okay. That's fine.
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A. Whatever I say about that point does
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not affect my conclusion.
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Q. And, in fact, you are not offering an
11
opinion in this case with respect to actual people
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in California, and more specifically, you're not
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offering an opinion in this case that every person
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in California would object to their information
15
being available in CLEAR; is that fair?
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A. I am offering the opinion based on
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research that the huge proportion of Americans
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including Californians want to control the
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information companies have about them.
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In the case of CLEAR, people don't even
21
know of its existence. My sense is that if you
22
told people what -- what is in my report, they
Case 3:21-cv-01418-EMC Document 166-3 Filed 03/06/23 Page 6 of 7
8/26/2022
Cat Brooks and Rasheed Shabazz, et al. v. Thomson Reuters Corp.
Joseph Turow, Ph.D.
Confidential
www.DigitalEvidenceGroup.com
Digital Evidence Group C'rt 2022
202-232-0646
Page 366
1
CERTIFICATE
2
I, Debra Sapio Lyons, a Registered
Diplomat Reporter, a Certified Realtime Reporter, a
3
Certified Realtime Captioner, an Approved Reporter
of the United States District Court for the Eastern
4
District of Pennsylvania, a Certified Court
Reporter for the State of New Jersey; and Notary
5
Public do hereby certify:
6
That Joseph Turow, Ph.D., the witness
whose deposition is hereinbefore set forth,
7
appeared remotely via Zoom videoconference, was
remotely sworn by me and that such deposition is a
8
true record of the testimony given by such witness,
to the best of my ability and thereafter reduced to
9
typewriting under my direction.
I further certify that I am not related to
10
any of the parties to this action by blood or
marriage and that I am in no way interested in the
11
outcome of the matter.
12
In witness whereof, I have hereunto set my
13
hand this 1st day of September, 2022.
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_____________________
20
DEBRA SAPIO LYONS
21
CRR, RDR, CRC, CCR, CPE
22
Case 3:21-cv-01418-EMC Document 166-3 Filed 03/06/23 Page 7 of 7File and source
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