Court filing
Declaration of Andre M. Mura — Brooks v. Thomson Reuters Corporation (Dkt. 167.2)
No. 3:21-cv-01418-EMC · Doc. 167-2 · Docket on CourtListener
Full text
Case 3:21-cv-01418-EMC Document 167-2 Filed 03/06/23 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 Hanne Jensen (SBN 336045) Washington, DC 20005
GIBBS LAW GROUP LLP Telephone: (202) 408-4600
5 1111 Broadway, Suite 2100 Facsimile: (202) 408-4699
6 Oakland, CA 94607 ggraber@cohenmilstein.com
Telephone: (510) 350-9700 kputtieva@cohenmilstein.com
7 Facsimile: (510) 350-9701
ehg@classlawgroup.com
8 amm@classlawgroup.com
amz@classlawgroup.com
9
mht@classlawgroup.com
10 zsw@classlawgroup.com
hj@classlawgroup.com
11
12 Attorneys for Plaintiffs and the Proposed Class
13
14
15 UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF CALIFORNIA
16 SAN FRANCISCO DIVISION
17 CAT BROOKS and RASHEED SHABAZZ, Case No. 3:21-cv-01418-EMC-KAW
18 individually and on behalf of all others similarly
situated, DECLARATION OF ANDRE M. MURA IN
19 SUPPORT OF PLAINTIFFS’
Plaintiffs, ADMINISTRATIVE MOTION TO
20 v. CONSIDER WHETHER ANOTHER
PARTY’S MATERIALS SHOULD BE
21
THOMSON REUTERS CORPORATION, SEALED
22
Defendant. Hon. Edward M. Chen
23
24
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 167-2 Filed 03/06/23 Page 2 of 3
1 I, Andre M. Mura, declare:
2 1. I am a member in good standing of the Bar of California and the bar of this Court. I am
3 a partner at Gibbs Law Group LLP in Oakland, California, and represent Plaintiffs in this matter.
4 2. I have personal knowledge of the facts set forth herein and, if called as a witness, could
5 and would testify competently to them.
6 3. I submit this declaration in support of Plaintiffs’ Administrative Motion to Consider
7 Whether Another Party’s Material Should Be Sealed.
8 4. Pursuant to Local Rule 79-5(f), I hereby state that the following documents, which are
9 exhibits to the Declaration of Andre M. Mura in Support of Plaintiffs’ Opposition to Defendant’s
10 Motion to Exclude Expert Testimony of Finance Scholars Group, Inc. (Terry Lloyd) have been
11 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
12 by Defendant under the operative Stipulated Protective Order in this action. See ECF No. 70:
13
Exhibits Portion Designated as “CONFIDENTIAL” or “HIGHLY
14 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” by
Defendant
15 Ex. 1 (Kidder Depo.) 43:13-43:23
Ex. 2 (Def.’s Fourth Supp. Entire document
16
Answers & Objections to
17 Pls.’ First Interrogatories)
18 5. The following portions of Plaintiffs’ Opposition to Defendant’s Motion to Exclude
19 Expert Testimony of Finance Scholars Group, Inc. (Terry Lloyd) (“Lloyd Opposition”) quote from or
20 otherwise refer to the exhibits referenced in Paragraph 4 above and so may also be potentially
21 considered confidential by Defendant:
22 Provisionally Sealed Portion of Lloyd Opposition
23 Page 8, line 22 (between “to be” and “TR”)
24
Page 8, line 22.5 (between “with a” and “search”)
25
Page 8, line 22.5 (between “field” and “percent”)
26
Page 8, line 23.5 (between “summing” and “column”)
27
Page 8, lines 23.5-24 (between “sum of” and “column”)
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 167-2 Filed 03/06/23 Page 3 of 3
1 6. The following portions of Plaintiffs’ Lloyd Opposition quote from or otherwise refer to
2 expert reports that were submitted under seal or designated under the parties’ protective order by
3 Defendant and so may also be potentially considered confidential by Defendant:
4
5 Provisionally Sealed Portion of Lloyd Opposition
6 Page 2, line 14 (between “there was a” and “between”)
Page 2, line 17 (between “that if” and “of CLEAR’s”
7
Page 2, line 18 (between “and” and “were”)
8 Page 2, line 22 (between “were” and “then”)
Page 6, lines 16-17 (entire parenthetical following “¶¶ 113-14”)
9 Page 6, line 22 (between “To be” and “Kidder”)
Page 6, line 23 (between “allocated” and end of sentence)
10
Page 8, line 10 (between “about” and “of CLEAR’s”)
11 Page 8, line 11 (between “and” and “are”)
Page 8, line 13 (between “them” and “to account”)
12
13 I declare that the foregoing is true and correct. Executed on March 6, 2022, in Oakland,
14 California.
15
16 /s/ Andre M. Mura
17 Andre M. Mura
18
19
20
21
22
23
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.374304.167.2.pdf
- Size
- 251,148 bytes
- SHA-256
- a7b8cbea34051048db4bfe735077c14d9a3dcd85ce623988802817da722ffa45
- Original
- PACER (login required)