Court filing

Declaration Rasheed Shabazz — Brooks v. Thomson Reuters Corporation (Dkt. 241.4)

Summary

Document 241-4, filed 08/29/24 in Case 3:21-cv-1418-EMC-KAW (Brooks v. Thomson Reuters Corporation, N.D. Cal.), is the Declaration of Rasheed Shabazz in Support of Plaintiffs' Motion for Preliminary Approval of Class Settlement, executed 08 / 08 / 2024. Shabazz describes himself as a journalist and community organizer and says he became a named Plaintiff because most Californians are not aware of CLEAR or that Thomson Reuters is selling access to their information. He lists his participation, including reviewing complaint drafts, producing documents, answering discovery and being deposed, and says he is happy with the settlement. He says it makes it easier for Californians to learn about CLEAR and get their information out of it, and requires Thomson Reuters to take steps to protect their privacy. A signature certificate follows.

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“Declaration Rasheed Shabazz — Brooks v. Thomson Reuters Corporation (Dkt. 241.4).” Original at ecf.cand.uscourts.gov, No. 3:21-cv-01418-EMC, Doc. 241-4. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-brooks-thomsonreuters-cand-374304/2024-08-29-gov-uscourts-cand-374304-241-4-gov-uscourts-cand-374304-241-4/, SHA-256 15ef5c9ab9226369ba615e1152b9e991ad9794dec626f7ab728af435c68b3200.

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Case 3:21-cv-01418-EMC Document 241-4 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 RASHEED SHABAZZ
19 IN SUPPORT OF PLAINTIFFS’ MOTION
Plaintiffs, FOR PRELIMINARY APPROVAL OF
20 v. CLASS SETTLEMENT
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THOMSON REUTERS CORPORATION,
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Defendant.
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DECLARATION OF RASHEED SHABAZZ IN SUPPORT OF PLAINTIFFS’ MOTION FOR
PRELIMINARY APPROVAL OF CLASS SETTLEMENT
Case No. 3:21-cv-1418-EMC-KAW

Document Ref: K9S8A-T8WE7-IQWDU-JMMXC Page 1 of 3
Case 3:21-cv-01418-EMC Document 241-4 Filed 08/29/24 Page 2 of 4

1 I, Rasheed Shabazz, 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 am a resident of Alameda, California, and am a journalist and community organizer.
7 I received a masters of City and Regional Planning at UC Berkeley, and I currently serve in a variety
8 of roles in which I work to inspire, support, and uplift voices in my community through public
9 history, multimedia, and youth development projects. I care deeply about issues of fairness affecting
10 my community and have spent considerable time and effort working to support people seeking
11 justice in housing, education, and other aspects of civic life.
12 3. I became a named Plaintiff in this class action because it is my understanding that
13 most Californians are not even aware of CLEAR or that Thomson Reuters is selling access to their
14 information to its customers. I believed that a class lawsuit would save time, money, and effort, and
15 help prevent Californians’ personal information from being made available without their knowledge
16 or consent.
17 4. As a named plaintiff, I have actively participated in this litigation. I helped review
18 drafts of the complaint. I searched for and produced relevant documents that I had. I worked closely
19 with Plaintiffs’ counsel to prepare responses to Thomson Reuters’ discovery requests. I was deposed
20 and I spent time with Plaintiffs’ counsel 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 and think the Court should
25 approve it. The settlement accomplishes what I hoped for when I decided to bring this case. It makes
26 it easier for Californians to learn about CLEAR. It makes it easier for Californians to get their
27 information out of CLEAR. And it requires Thomson Reuters to take steps to be protective of
28 Californians’ privacy while they operate CLEAR.
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DECLARATION OF RASHEED SHABAZZ IN SUPPORT OF PLAINTIFFS’ MOTION FOR
PRELIMINARY APPROVAL OF CLASS SETTLEMENT
Case No. 3:21-cv-1418-EMC-KAW

Document Ref: K9S8A-T8WE7-IQWDU-JMMXC Page 2 of 3
Case 3:21-cv-01418-EMC Document 241-4 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
08 / 08 / 2024
13 on_________________________.
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Rasheed Shabazz
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DECLARATION OF RASHEED SHABAZZ IN SUPPORT OF PLAINTIFFS’ MOTION FOR
PRELIMINARY APPROVAL OF CLASS SETTLEMENT
Case No. 3:21-cv-1418-EMC-KAW

Document Ref: K9S8A-T8WE7-IQWDU-JMMXC Page 3 of 3
Case 3:21-cv-01418-EMC Document 241-4 Filed 08/29/24 Page 4 of 4

Signature Certificate
Reference number: K9S8A-T8WE7-IQWDU-JMMXC

Signer Timestamp Signature

Rasheed Shabazz
Email: rasheed@berkeley.edu

Sent: 07 Aug 2024 16:10:13 UTC
Viewed: 08 Aug 2024 17:49:19 UTC
Signed: 08 Aug 2024 18:01:45 UTC

Recipient Verification: IP address: 207.151.52.244
✔Email verified 08 Aug 2024 17:49:19 UTC Location: Los Angeles, United States

Document completed by all parties on:
08 Aug 2024 18:01:45 UTC

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File: gov.uscourts.cand.374304.241.4.pdf
Size: 810,494 bytes
SHA-256: 15ef5c9ab9226369ba615e1152b9e991ad9794dec626f7ab728af435c68b3200
Our copy: gov.uscourts.cand.374304.241.4.pdf
Original: PACER (login required)