Declaration of Rasheed Shabazz — Brooks v. Thomson Reuters Corporation (Dkt. 264.3)

Summary

The Declaration of Rasheed Shabazz in Support of Plaintiffs' Motion for Attorneys' Fees, Costs, and Service Awards, Document 264-3, filed 10/25/24 in Case No. 3:21-cv-1418-EMC-KAW, Cat Brooks and Rasheed Shabazz v. Thomson Reuters Corporation, Northern District of California, three pages. Shabazz declares under penalty of perjury that, as a named plaintiff, he reviewed drafts of the complaint, produced documents, helped prepare discovery responses and was deposed. He estimates that he spent about 35 hours on the case, including around 8 hours preparing for the deposition. He states that he is happy with the settlement terms and thinks the Court should approve them, and that he understands he is entitled only to the rights of settlement class members. The signature block names Rasheed Shabazz with a date of 10 / 17 / 2024.

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                  Case 3:21-cv-01418-EMC         Document 264-3    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

      8
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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 RASHEED SHABAZZ
     19                                                       IN SUPPORT OF PLAINTIFFS’ MOTION
     20                       Plaintiffs,                     FOR ATTORNEYS’ FEES, COSTS, AND
                    v.                                        SERVICE AWARDS
     21
     22    THOMSON REUTERS CORPORATION,

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

Document Ref: T4EOM-9WVAA-KXIBW-P3L4Q                                                             Page 1 of 3
                  Case 3:21-cv-01418-EMC          Document 264-3        Filed 10/25/24    Page 2 of 3




      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
      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 am a resident of Alameda, California, and am a journalist and community
      7    organizer. I received a masters of City and Regional Planning at UC Berkeley, and I
      8    currently serve in a variety of roles in which I work to inspire, support, and uplift voices in
      9    my community through public history, multimedia, and youth development projects. I care
     10    deeply about issues of fairness affecting my community and have spent considerable time
     11    and effort working to support people seeking justice in housing, education, and other
     12    aspects of civic life.
     13             3.       I became a named Plaintiff in this class action because it is my understanding
     14    that most Californians are not even aware of CLEAR or that Thomson Reuters is selling
     15    access to their information to its customers. I believed that a class lawsuit would save time,
     16    money, and effort, and help prevent Californians’ personal information from being made
     17    available without their knowledge or consent.
     18             4.       As a named plaintiff, I have actively participated in this litigation. I helped
     19    review drafts of the complaint. I searched for and produced relevant documents that I had.
     20    I worked closely with Plaintiffs’ counsel to prepare responses to Thomson Reuters’
     21    discovery requests. I was deposed and I spent time with Plaintiffs’ counsel preparing for
     22    that deposition.
     23             5.       Throughout my time as a named plaintiff, I have kept in touch with Plaintiffs’
     24    counsel and received regular updates on the case. Plaintiffs’ counsel has also reviewed the
     25    terms of the settlement agreement with me.
     26             6.       In all, I would estimate that I spent about 35 hours working on this case. I
     27    spent around 8 hours preparing for my deposition, and was deposed for about 7 hours in-
     28    person. I worked with my lawyers to collect documents that might be responsive to
                                                  1
              DECLARATION OF RASHEED SHABAZZ IN SUPPORT OF PLAINTIFFS’ MOTION FOR
                         ATTORNEYS’ FEES, COSTS, AND SERVICE AWARDS
                                  Case No. 3:21-cv-1418-EMC-KAW

Document Ref: T4EOM-9WVAA-KXIBW-P3L4Q                                                                          Page 2 of 3
                  Case 3:21-cv-01418-EMC          Document 264-3       Filed 10/25/24    Page 3 of 3




      1    Thomson Reuters’ discovery requests, which took a good amount of time. I would meet
      2    with my lawyers periodically to get regular case updates. The rest of the time was spent
      3    working on the complaint, responding to Thomson Reuters’ interrogatories, and discussing
      4    the settlement with my lawyers.
      5             7.       I am happy with the terms of the settlement agreement and think the Court
      6    should approve it. The settlement accomplishes what I hoped for when I decided to bring
      7    this case. It makes it easier for Californians to learn about CLEAR. It makes it easier for
      8    Californians to get their information out of CLEAR. And it requires Thomson Reuters to
      9    take steps to be protective of Californians’ privacy while they operate CLEAR.
     10             8.       When we asked the Court to certify a class in this case, I declared that I
     11    understood the responsibilities of a class representative to protect the interests of the class,
     12    that I was prepared to serve in that role, and that I was unaware of any conflict that would
     13    prevent me from fairly or adequately representing the class. I remain willing and able to
     14    perform all of the duties and obligations of a representative of the settlement class until this
     15    matter is finally resolved.
     16             9.       I also understand that I am entitled to only the rights and remedies of
     17    settlement class members under the settlement agreement, and not to any additional
     18    compensation by virtue of my status as a settlement class representative.
     19             I declare under penalty of perjury that the foregoing is true and correct. Executed
     20       10 / 17 / 2024
           on_________________________.                                ________________________
     21                                                                Rasheed Shabazz
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              DECLARATION OF RASHEED SHABAZZ IN SUPPORT OF PLAINTIFFS’ MOTION FOR
                         ATTORNEYS’ FEES, COSTS, AND SERVICE AWARDS
                                  Case No. 3:21-cv-1418-EMC-KAW

Document Ref: T4EOM-9WVAA-KXIBW-P3L4Q                                                                     Page 3 of 3


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