Court filing

Declaration of Cat Brooks — Brooks v. Thomson Reuters Corporation (Dkt. 264.2)

Summary

Declaration of Cat Brooks in Support of Plaintiffs' Motion for Attorneys' Fees, Costs, and Service Awards, Document 264-2, filed 10/25/24 in Brooks v. Thomson Reuters Corporation, Case No. 3:21-cv-1418-EMC-KAW (N.D. Cal.). Brooks describes herself as an Oakland activist, organizer, playwright and performer and says she became a named Plaintiff because most Californians are not aware of CLEAR. She says she helped review the complaint, produced documents, was deposed, and spent about 45 hours on the case. She says she is happy with the settlement agreement, understands she is entitled only to the rights of settlement class members and not additional compensation, and declares under penalty of perjury.

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“Declaration of Cat Brooks — Brooks v. Thomson Reuters Corporation (Dkt. 264.2).” Original at ecf.cand.uscourts.gov, No. 3:21-cv-01418-EMC, Doc. 264-2. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-brooks-thomsonreuters-cand-374304/2024-10-25-gov-uscourts-cand-374304-264-2-gov-uscourts-cand-374304-264-2/, SHA-256 49502c661587d1f56480c4e7f443de75573d3f551cf5f9d6de97ca378f9332e0.

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Case 3:21-cv-01418-EMC Document 264-2 Filed 10/25/24 Page 1 of 3

1 Andre M. Mura (SBN 298541) Geoffrey A. Graber (SBN 211547)
Ezekiel S. Wald (SBN 341490) Karina G. Puttieva (SBN 317702)
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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 Certified Class
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UNITED STATES DISTRICT COURT FOR THE
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NORTHERN DISTRICT OF CALIFORNIA
16 SAN FRANCISCO DIVISION
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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
20 Plaintiffs, ATTORNEYS’ FEES, COSTS, AND
v. SERVICE AWARDS
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22 THOMSON REUTERS CORPORATION,

23 Defendant.
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DECLARATION OF CAT BROOKS IN SUPPORT OF PLAINTIFFS’ MOTION FOR
ATTORNEYS’ FEES, COSTS, AND SERVICE AWARDS
Case No. 3:21-cv-1418-EMC-KAW

Document Ref: HCQU6-TKFGT-SSZJ4-QHFUW Page 1 of 3
Case 3:21-cv-01418-EMC Document 264-2 Filed 10/25/24 Page 2 of 3

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
3 upon to do so, could and would testify competently to the facts contained in this
4 declaration. I understand that this declaration will be used to support Plaintiffs’ motion for
5 attorneys’ fees, costs, and service awards 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
8 Project, and I host the radio show Law & Disorder on KPFA. I was raised in an activist
9 household and have dedicated my life to improving the lives of people in my community
10 and bringing awareness to 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
12 that most Californians are not even aware of CLEAR and may not know that Thomson
13 Reuters is selling access to their information to its customers. I believed that a class lawsuit
14 would save time, money, and effort, and help prevent Californians’ personal information
15 from being made available without their knowledge or consent.
16 4. As a named plaintiff, I have actively participated in this litigation. Among
17 other things, I helped review drafts of the complaint. During discovery, I searched for and
18 produced relevant documents that I had. I worked closely with Plaintiffs’ counsel to
19 prepare responses to Thomson Reuters’ discovery requests. And I was deposed and spent
20 time with Plaintiffs’ counsel preparing for that deposition.
21 5. Throughout my time as a named plaintiff, I have kept in touch with Plaintiffs’
22 counsel and received regular updates on the case. Plaintiffs’ counsel has also reviewed the
23 terms of the settlement agreement with me.
24 6. In all, I would estimate that I spent about 45 hours working on this case. I was
25 deposed for about 7 hours, and spent about that same amount of time preparing for the
26 deposition with my lawyers. I spent a lot of time looking for documents and collecting my
27 emails for review. I would meet with my lawyers periodically to get regular case updates.
28 And I spent time working with my lawyers on the complaint. The rest of the time was
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DECLARATION OF CAT BROOKS IN SUPPORT OF PLAINTIFFS’ MOTION FOR
ATTORNEYS’ FEES, COSTS, AND SERVICE AWARDS
Case No. 3:21-cv-1418-EMC-KAW

Document Ref: HCQU6-TKFGT-SSZJ4-QHFUW Page 2 of 3
Case 3:21-cv-01418-EMC Document 264-2 Filed 10/25/24 Page 3 of 3

1 spent working on responses to Thomson Reuters’ interrogatories, generally keeping up
2 with the status of the litigation, reviewing and discussing the settlement, and working on
3 administrative tasks with my lawyers.
4 7. I am happy with the terms of the settlement agreement. I think the Court
5 should approve it. I think it’s great. The lawyers did a great job and the benefits for
6 Californians are what I was hoping for when I brought this lawsuit. I think this settlement
7 will help other Californians learn about CLEAR and more easily remove their information
8 from CLEAR and the sources that supply it.
9 8. When we asked the Court to certify a class in this case, I declared that I
10 understood the responsibilities of a class representative to protect the interests of the class,
11 that I was prepared to serve in that role, and that I was unaware of any conflict that would
12 prevent me from fairly or adequately representing the class. I remain willing and able to
13 perform all of the duties and obligations of a representative of the settlement class until this
14 matter is finally resolved.
15 9. I also understand that I am entitled to only the rights and remedies of
16 settlement class members under the settlement agreement, and not to any additional
17 compensation by virtue of my status as a settlement class representative.
18 I declare under penalty of perjury that the foregoing is true and correct. Executed on
19 10 / 17 / 2024
________________________. ______________________________
20 Cat Brooks
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DECLARATION OF CAT BROOKS IN SUPPORT OF PLAINTIFFS’ MOTION FOR
ATTORNEYS’ FEES, COSTS, AND SERVICE AWARDS
Case No. 3:21-cv-1418-EMC-KAW

Document Ref: HCQU6-TKFGT-SSZJ4-QHFUW Page 3 of 3

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File: gov.uscourts.cand.374304.264.2.pdf
Size: 174,988 bytes
SHA-256: 49502c661587d1f56480c4e7f443de75573d3f551cf5f9d6de97ca378f9332e0
Our copy: gov.uscourts.cand.374304.264.2.pdf
Original: PACER (login required)