Court filing

Declaration of Cat Brooks — Brooks v. Thomson Reuters Corporation (Dkt. 241.3)

Summary

Document 241-3, filed 08/29/24 in Case No. 3:21-cv-1418-EMC-KAW, is the Declaration of Cat Brooks in support of Plaintiffs' motion for preliminary approval of class settlement. She says she is an activist, organizer, playwright and performer in Oakland, California, and became a named Plaintiff because most Californians are not aware of CLEAR. She describes helping review drafts of the complaint, producing documents, preparing discovery responses and being deposed. She says she is happy with the settlement terms, thinks the Court should approve it, and expects it to help Californians learn about CLEAR and remove their information. She also says she is entitled only to the rights of settlement class members and not additional compensation, and a signature certificate shows she signed on 09 Aug 2024.

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Cite this document

“Declaration of Cat Brooks — Brooks v. Thomson Reuters Corporation (Dkt. 241.3).” Original at ecf.cand.uscourts.gov, No. 3:21-cv-01418-EMC, Doc. 241-3. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-brooks-thomsonreuters-cand-374304/2024-08-29-gov-uscourts-cand-374304-241-3-gov-uscourts-cand-374304-241-3/, SHA-256 45cb802ade71e4df03c734db138040d572657ae48e387203847abd441b31ca18.

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Case 3:21-cv-01418-EMC Document 241-3 Filed 08/29/24 Page 1 of 4

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 Telephone: (510) 350-9700 Washington, DC 20005
Facsimile: (510) 350-9701 Telephone: (202) 408-4600
5 amm@classlawgroup.com Facsimile: (202) 408-4699
6 zsw@classlawgroup.com ggraber@cohenmilstein.com
kputtieva@cohenmilstein.com
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12 Attorneys for Plaintiffs and the Class
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UNITED STATES DISTRICT COURT FOR THE
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NORTHERN DISTRICT OF CALIFORNIA
16 SAN FRANCISCO DIVISION

17 CAT BROOKS and RASHEED SHABAZZ, Case No. 3:21-cv-1418-EMC-KAW
18 individually and on behalf of all others similarly
situated, DECLARATION OF CAT BROOKS IN
19 SUPPORT OF PLAINTIFFS’ MOTION FOR
Plaintiffs, PRELIMINARY APPROVAL OF CLASS
20 v. SETTLEMENT
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THOMSON REUTERS CORPORATION,
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Defendant.
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DECLARATION OF CAT BROOKS IN SUPPORT OF PLAINTIFFS’ MOTION FOR
PRELIMINARY APPROVAL OF CLASS SETTLEMENT
Case No. 3:21-cv-1418-EMC-KAW

Document Ref: AURHT-EEZXU-MMVF8-7SPEY Page 1 of 3
Case 3:21-cv-01418-EMC Document 241-3 Filed 08/29/24 Page 2 of 4

1 I, Cat Brooks, declare under penalty of perjury:
2 1. I base this declaration on my personal knowledge of the facts and, if called upon to do
3 so, could and would testify competently to the facts contained in this declaration. I understand that
4 this declaration will be used to support Plaintiffs’ motion for preliminary approval of the class action
5 settlement in the above-captioned case.
6 2. I live in Oakland, California, and am an activist, organizer, playwright, and
7 performer. I am the executive director of Justice Teams Network and the Anti-Police-Terror Project,
8 and I host the radio show Law & Disorder on KPFA. I was raised in an activist household and have
9 dedicated my life to improving the lives of people in my community and bringing awareness to
10 injustices we face through politics, writing, art, and other media.
11 3. I became a named Plaintiff in this class action because it is my understanding that
12 most Californians are not even aware of CLEAR and may not know that Thomson Reuters is selling
13 access to their information to its customers. I believed that a class lawsuit would save time, money,
14 and effort, and help prevent Californians’ personal information from being made available without
15 their knowledge or consent.
16 4. As a named plaintiff, I have actively participated in this litigation. Among other
17 things, I helped review drafts of the complaint. During discovery, I searched for and produced
18 relevant documents that I had. I worked closely with Plaintiffs’ counsel to prepare responses to
19 Thomson Reuters’ discovery requests. And I was deposed and spent time with Plaintiffs’ counsel
20 preparing for that deposition.
21 5. Throughout my time as a named plaintiff, I have kept in touch with Plaintiffs’ counsel
22 and received regular updates on the case. Plaintiffs’ counsel has also reviewed the terms of the
23 settlement agreement with me.
24 6. I am happy with the terms of the settlement agreement. I think the Court should
25 approve it. I think it’s great. The lawyers did a great job and the benefits for Californians are what I
26 was hoping for when I brought this lawsuit. I think this settlement will help other Californians learn
27 about CLEAR and more easily remove their information from CLEAR and the sources that supply it.
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DECLARATION OF CAT BROOKS IN SUPPORT OF PLAINTIFFS’ MOTION FOR
PRELIMINARY APPROVAL OF CLASS SETTLEMENT
Case No. 3:21-cv-1418-EMC-KAW

Document Ref: AURHT-EEZXU-MMVF8-7SPEY Page 2 of 3
Case 3:21-cv-01418-EMC Document 241-3 Filed 08/29/24 Page 3 of 4

1 7. When we asked the Court to certify a class in this case, I declared that I understood
2 the responsibilities of a class representative to protect the interests of the class, that I was prepared to
3 serve in that role, and that I was unaware of any conflict that would prevent me from fairly or
4 adequately representing the class. I remain willing and able to perform all of the duties and
5 obligations of a representative of the settlement class until this matter is finally resolved.
6 8. I also understand that I am entitled to only the rights and remedies of settlement class
7 members under the settlement agreement, and not to any additional compensation by virtue of my
8 status as a settlement class representative.
9 9. I authorize Class Counsel Andre Mura and Geoffrey Graber to enter into this
10 Agreement with respect to the claims asserted in the action and any other claims covered by the
11 release.
12 I declare under penalty of perjury that the foregoing is true and correct. Executed on
08 / 09 / 2024
13 ________________________.
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Cat Brooks
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DECLARATION OF CAT BROOKS IN SUPPORT OF PLAINTIFFS’ MOTION FOR
PRELIMINARY APPROVAL OF CLASS SETTLEMENT
Case No. 3:21-cv-1418-EMC-KAW

Document Ref: AURHT-EEZXU-MMVF8-7SPEY Page 3 of 3
Case 3:21-cv-01418-EMC Document 241-3 Filed 08/29/24 Page 4 of 4

Signature Certificate
Reference number: AURHT-EEZXU-MMVF8-7SPEY

Signer Timestamp Signature

Cat Brooks
Email: cat@justiceteams.org

Sent: 07 Aug 2024 16:09:35 UTC
Viewed: 09 Aug 2024 16:22:59 UTC
Signed: 09 Aug 2024 16:23:09 UTC

Recipient Verification: IP address: 76.21.29.163
✔Email verified 09 Aug 2024 16:22:59 UTC Location: Oakland, United States

Document completed by all parties on:
09 Aug 2024 16:23:09 UTC

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File: gov.uscourts.cand.374304.241.3.pdf
Size: 807,862 bytes
SHA-256: 45cb802ade71e4df03c734db138040d572657ae48e387203847abd441b31ca18
Our copy: gov.uscourts.cand.374304.241.3.pdf
Original: PACER (login required)