Declaration of Jonathan P. Shaffer of Angeion Group — Brooks v. Thomson Reuters Corporation (Dkt. 295.1)

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Declaration of Jonathan P. Shaffer, an Associate Project Director at Angeion Group, on the status of the distribution in Brooks and Shabazz v. Thomson Reuters Corporation, Case No. 3:21-cv-01418-EMC-KAW (N.D. Cal.), Document 295-1, filed 03/05/26, two pages. He says Angeion sent payments to valid claimants on April 15, 2025 and that the initial deadline to cash checks was May 7, 2025. As of February 24, 2026, 116,542 electronic payments were attempted, with 114,539 successful totaling $17,878,392.51 and 2,003 unsuccessful totaling $312,648.27; those were mailed checks. Angeion distributed 10,713 checks, of which 9,899 were cashed for $1,545,134.91 and 814 remained uncashed at $127,057.26. The Settlement Fund then contained $122,101.51, a gap he attributes to late payments to claimants first marked fraudulent who later showed they were legitimate. He executed it on March 3, 2026.

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      Case 3:21-cv-01418-EMC           Document 295-1    Filed 03/05/26   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 MURA LLP                                     COHEN MILSTEIN SELLERS &
     1111 Broadway, Suite 2100                          TOLL PLLC
 3
     Oakland, CA 94607                                  1100 New York Ave. NW, Suite 800
 4   Telephone: (510) 350-9700                          Washington, DC 20005
     Facsimile: (510) 350-9701                          Telephone: (202) 408-4600
 5   amm@classlawgroup.com                              Facsimile: (202) 408-4699
     zsw@classlawgroup.com                              ggraber@cohenmilstein.com
 6                                                      kputtieva@cohenmilstein.com
 7
     Attorneys for Plaintiffs and the Class
 8

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                                 UNITED STATES DISTRICT COURT
11
                               NORTHERN DISTRICT OF CALIFORNIA
12                                  SAN FRANCISCO DIVISION

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14 CAT BROOKS and RASHEED SHABAZZ,                      Case No. 3:21-cv-01418-EMC-KAW
   individually and on behalf of all others
15 similarly situated,                                  DECLARATION OF JONATHAN P.
                            Plaintiff,                  SHAFFER RE: DISTRIBUTION
16                                                      STATUS
                         v.
17

18 THOMSON REUTERS CORPORATION,

19                               Defendants.

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      Case 3:21-cv-01418-EMC           Document 295-1        Filed 03/05/26    Page 2 of 2




 1 I, Jonathan P. Shaffer, declare and state as follows:

 2          1.      I am an Associate Project Director with Angeion Group (“Angeion”), located at 1650

 3 Arch Street, Suite 2210, Philadelphia, PA 19103. I am over 21 years of age and am not a party to this

 4 action and I have personal knowledge of the facts set forth herein.

 5          2.     On April 15, 2025, Angeion sent distribution payments to the claimants who submitted

 6 valid claims. The initial deadline for Settlement Class Members to cash their Individual Class

 7 Payment check was May 7, 2025.

 8          3.     As of February 24, 2026, A total of 116,542 electronic payments were attempted. Of

 9 these, 114,539 payments were successful totaling $17,878,392.51 and 2,003 payments were

10 ultimately unsuccessful totaling $312,648.27. Electronic payments that were deemed ultimately

11 unsuccessful were mailed a check.

12          4.     As of February 24, 2026, Angeion distributed 10,713 Checks. Of these, 9,899 checks

13 were cashed, totaling $1,545,134.91 and 814 checks remained uncashed totaling $127,057.26.

14          5.     As of February 24, 2026, the total remaining in the Settlement Fund is $122,101.51.

15          6.     The reason the uncashed checks balance reflected in paragraph 4 exceeds the total

16 remaining in the settlement fund reflected in paragraph 5 is because as the distribution proceeded

17 (following the initial calculation of the distribution amount), a small number of claimants who were

18 initially marked as fraudulent communicated with Angeion and ultimately demonstrated their

19 legitimacy. Angeion paid these claimants accordingly, in conjunction with receiving interest

20 payments on the fund, according to the claimants’ preferred payment method (i.e., not all of them

21 were paid via checks). Because of those additional payments, there is a minor difference between the

22 total uncashed funds and amount remaining in the Settlement Fund.

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24 I declare under penalty of perjury under the laws of the United States of America that the foregoing

25 is true and correct.

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27 Executed on March 3, 2026.

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                                                           JONATHAN P. SHAFFER
                                             1
                 DECLARATION OF JONATHAN P. SHAFFER RE: DISTRIBUTION STATUS


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