Declaration of Andre M. Mura — Brooks v. Thomson Reuters Corporation (Dkt. 240.1)

Summary

Document 240-1, filed 08/29/24 in Case 3:21-cv-01418-EMC-KAW (Brooks v. Thomson Reuters Corporation, N.D. Cal.), is the Declaration of Andre M. Mura, a partner at Gibbs Law Group LLP, in support of Plaintiffs' Administrative Motion to File Under Seal. Under Local Rule 79-5(c), he states that a portion of the Parties' Master Settlement Agreement, Exhibit 1 to the declaration supporting the Motion for Preliminary Approval of Class Action Settlement, refers to the specific opt-out threshold that would trigger settlement failure. The portion identified is the first sentence of Section VII, paragraph 7, which continues that Thomson Reuters may elect to terminate the Agreement. The threshold figure itself is not shown, and the declaration is dated August 29, 2024.

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          Case 3:21-cv-01418-EMC              Document 240-1   Filed 08/29/24   Page 1 of 2




 1    Andre M. Mura (SBN 298541)                         Geoffrey A. Graber (SBN 211547)
      Ezekiel S. Wald (SBN 341490)                       Karina G. Puttieva (SBN 317702)
 2
      GIBBS LAW GROUP LLP                                COHEN MILSTEIN SELLERS & TOLL
 3    1111 Broadway, Suite 2100                          PLLC
      Oakland, CA 94607                                  1100 New York Ave. NW, Fifth Floor
 4                                                       Washington, DC 20005
      Telephone: (510) 350-9700
 5    Facsimile: (510) 350-9701                          Telephone: (202) 408-4600
      amm@classlawgroup.com                              Facsimile: (202) 408-4699
 6    zsw@classlawgroup.com                              ggraber@cohenmilstein.com
 7                                                       kputtieva@cohenmilstein.com

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12   Attorneys for Plaintiffs and the Class
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15                          UNITED STATES DISTRICT COURT FOR THE
                              NORTHERN DISTRICT OF CALIFORNIA
16                                SAN FRANCISCO DIVISION
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     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
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                                                        SUPPORT OF PLAINTIFFS’
20                  Plaintiffs,                         ADMINISTRATIVE MOTION TO FILE
            v.                                          UNDER SEAL
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22   THOMSON REUTERS CORPORATION,                       Hon. Edward M. Chen

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                    Defendant.
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                 DECLARATION OF ANDRE M. MURA IN SUPPORT OF PLAINTIFFS’
                       ADMINISTRATIVE MOTION TO FILE UNDER SEAL
                              Case No. 3:21-cv-01418-EMC-KAW
          Case 3:21-cv-01418-EMC         Document 240-1       Filed 08/29/24    Page 2 of 2




 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
 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 File
 8   Under Seal.
 9          4.      Pursuant to Local Rule 79-5(c), I hereby state that the following portions of the
10   Parties’ Master Settlement Agreement (“Settlement”), which is attached as Exhibit 1 to the
11   Declaration of Andre Mura and Geoffrey Graber in Support of Plaintiffs’ Motion for
12   Preliminary Approval of Class Action Settlement, refer to the specific opt-out threshold that
13   would trigger settlement failure here.
14           Portion of Settlement
15           Section VII, paragraph 7, first sentence (between “timely requests for exclusion
16           exceeds” and “, Thomson Reuters may elect to terminate this Agreement”)
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18          I declare that the foregoing is true and correct. Executed on August 29, 2024.

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20                                                     /s/ Andre M. Mura
                                                       Andre M. Mura
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                                               1
                 DECLARATION OF ANDRE M. MURA IN SUPPORT OF PLAINTIFFS’
                       ADMINISTRATIVE MOTION TO FILE UNDER SEAL
                              Case No. 3:21-cv-01418-EMC-KAW


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