[Proposed] Amended Stipulation and Order for Fact Deposition Protocol and Coordination — United States of America v. Visa Inc., Case No. 1:24-cv-7214-JGK-SLC (Dkt. 165)

Summary

The proposed amended stipulation and order for fact deposition protocol and coordination, dated June 15, 2026 and submitted subject to Court approval, would set the rules for fact depositions in United States v. Visa Inc., No. 1:24-cv-7214-JGK-SLC, and the consolidated class actions In re: Visa Debit Card Antitrust Litigation, No. 1:24-cv-7435-JGK-SLC (S.D.N.Y.). It would supersede the stipulation and order of March 9, 2026 and addresses coordination, not consolidation. Under prior orders the Government and Visa are each limited to 350 hours of deposition time and the private plaintiffs to 125 hours. Each deposition is to last a single day and no more than 7 hours on the record unless the protocol provides otherwise. Only one attorney per party may examine a witness, though the private plaintiffs may have two, one each for the merchant and cardholder plaintiffs.

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

IN RE: VISA DEBIT CARD ANTITRUST Case No.: 1:24-cv-7435-JGK-SLC
LITIGATION

UNITED STATES OF AMERICA,
Plaintiff,
Vv. Case No.: 1:24-cv-7214-JGK-SLC
VISA INC.
Defendant.

PROPOSED) AMENDED STIPULATION AND ORDER FOR FACT DEPOSITION
YvUY PROTOCOL AND COORDINATION

WHEREAS, the United States of America (the “United States” or “Government”) has filed
suit against Visa Inc. (“Visa”) in a suit styled United States of America v. Visa Inc., 1:24-cv-7214-
JGK-SLC (the “DOJ Action”);

WHEREAS, two putative class actions, one brought by merchants (“Merchant Plaintiffs”) and
one brought by cardholders (“Cardholder Plaintiffs” and, jointly, “Private Plaintiffs”), against Visa
have been consolidated in this Court as In re: Visa Debit Card Antitrust Litigation, 1:24-cv-7435-
JGK-SLC (the “Private Actions” and, together with the DOJ Action, the “Coordinated Actions”);

WHEREAS, the United States, Visa, and Private Plaintiffs (together, the “Parties,” and each a
“Party”') believe that coordination of fact discovery, particularly depositions, in the Coordinated

Actions will promote efficiency, minimize expenses, and avoid duplication of effort;

‘Unless otherwise stated, Private Plaintiffs are a single “Party” for the purposes of this Order.
WHEREAS, the Parties have met and conferred and agreed, subject to Court approval, on the
topics outlined in this to this [Proposed] Amended Stipulation and Order for Deposition Protocol
and Coordination (the “Order” or “Protocol’’) in the Coordinated Actions, which supersedes the
Stipulation and Order for Deposition Protocol and Coordination of March 9, 2026;

IT IS HEREBY STIPULATED AND ORDERED AS FOLLOWS:

I. GENERAL PROVISIONS

1. The Parties shall endeavor in good faith, wherever reasonably feasible, to
coordinate discovery, minimize burden, encourage efficiency, and avoid unnecessary expense for
all Parties and non-parties.

2. This Order shall govern all fact depositions of non-party and Party witnesses,
including depositions taken pursuant to Federal Rule of Civil Procedure (“FRCP”) 30(b)(1) and
FRCP 30(b)(6) (i.e., all depositions other than expert depositions), in the Coordinated Actions.

3. This Order addresses only coordination, not consolidation. Nothing in this Order
shall be construed to imply that any Party consents to additional consolidation of the Private
Actions, consolidation of the DOJ Action and the Private Actions, or that such consolidation is
appropriate.

4. Absent agreement of the Parties or order of the Court, any matter not expressly
addressed in this Protocol shall be governed by the applicable Federal Rules of Civil Procedure,
Federal Rules of Evidence, the Local Rules of the United States District Court for the Southern
District of New York, and the prior orders of the Court in the Coordinated Actions.

5. The Parties will work collaboratively and in good faith to address any issues not

expressly addressed by this Protocol.
6. This Order supersedes any prior conflicting provisions related to fact depositions
in agreements and orders previously entered in these Coordinated Actions.

7. Absent agreement of the Parties and, if applicable, the non-party, no deposition
shall be scheduled to take place less than two weeks from the date the deposition notice for that
deposition is served.

8. Private Plaintiffs hereby expressly agree that the Stipulation and Order Regarding
Protocol for Remote Depositions (Dkt. No. 111) (the “Remote Deposition Protocol’) in the DOJ
Action shall apply to the Private Actions as if stipulated to and ordered therein, except that the
Parties agree (a) that AgileLaw is an acceptable “secure file sharing platform” for purposes of
Paragraph 22 of the Remote Deposition Protocol so long as all Parties, upon good faith efforts, are
able to access documents presented on that platform, and (b) to negotiate in good faith, when
requested, alternative means for distributing printed copies of potential exhibits for remote
depositions in lieu of the procedure laid out in Paragraph 23 of the Remote Deposition Protocol.

9. Except by agreement of the Parties, by leave or previous order of the Court, or as
otherwise set forth herein (see infra Sections III, IV), each deposition shall take place during a
single day and last no more than 7 hours on the record.

10. ‘In the case of a deposition that will extend beyond 7 hours (including certain non-
party depositions for up to 14 total hours under Section IV of this Protocol and certain Visa
depositions for up to 10 total hours under Section III), the witness may elect to have the deposition

occur over two consecutive business days (or non-consecutive business days if the Parties and/or

non-party all agree).
11. The Parties may, by mutual agreement, schedule a deposition after the close of fact
discovery without seeking leave of Court; if the Parties so agree, its content will not be
objectionable purely on timeliness grounds.

12. All notices of depositions shall be served on all Parties whose cases have not been
settled or dismissed, regardless of whether the deposition is noticed in the DOJ Action, the Private
Action, or both.

13. This stipulation is without prejudice to the rights of any Party or non-Party to object
to the noticing of or questioning during any particular deposition or to seek relief from or
modification of this stipulation from the Court.

14. Absent agreement of all Parties and, if applicable, the non-party, or order of the
Court, there shall be no more than one FRCP 30(b)(1) deposition per witness across the
Coordinated Actions.

15. After a Party notices a deposition in the DOJ Action, the Private Actions, or both,
any other Party may cross-notice the deposition in the actions to which they are a Party.

16. The Parties shall be able to use for all purposes, including, but not limited to,
deposition designations at trial, any fact deposition testimony (including testimony taken pursuant
to FRCP 30(b)(6)) taken in either of the Coordinated Actions, including transcripts and
accompanying exhibits, in either the DOJ Action or Private Actions as if the deposition was taken
in that case.

17. Only one attorney per Party may examine a witness during a deposition, though
Private Plaintiffs may elect to have two examining attorneys, one for each of the (a) Merchant

Plaintiffs and (b) Cardholder Plaintiffs.
18. Any objection by the Government or Private Plaintiffs shall be deemed to have been
made on behalf of both the Government and Private Plaintiffs. Counsel need not repeat another
counsel’s objection to preserve that objection, and counsel shall avoid repeating objections already
preserved. Speaking objections are forbidden, and counsel shall not interpose objections to
unreasonably disrupt the deposition. All objections shall be stated concisely in a non-
argumentative and non-suggestive manner in compliance with the FRCP and all other applicable
rules.

19. No person shall engage in a private communication, including through text
message, electronic mail, handwritten notes, hand gestures, or the chat feature in the
videoconferencing system, with the deponent while the deposition is on the record. If counsel
intends to initiate a private communication with any deponent to determine whether a privilege
should be asserted, counsel shall state their intention on the record before initiating such
communication, and then the deposition shall go off the record. Nothing in this paragraph is
intended to alter any local or federal rules governing communications with witnesses during a
deposition.

20. In the event of a dispute during a deposition (whether noticed pursuant to FRCP
30(b)(1) or 30(b)(6)), the Parties and/or non-party shall memorialize the dispute on the record and
present the dispute to the Court by motion no later than 7 business days after the dispute arose. If
the Court orders a Party or non-party to provide additional testimony (i.e., overrules the objection
of the Party or non-party to answering a particular question), the Party or non-party shall provide
the witness for deposition on the testimony in question within 10 business days of the ruling or
another mutually agreeable date as determined by the Parties (and if, applicable, non-party) to the

deposition.
II. ALLOCATION OF TIME

21. Pursuant to the prior orders of the Court (United States v. Visa, Dkt. Nos. 53, 100;
In re Visa Debit Litigation, Dkt. Nos. 98, 184), the Parties are limited to the following number of
total on-the-record deposition hours:

a. The Government is limited to a total of 350 hours;
b. Private Plaintiffs are limited to a total of 125 hours;
c. Visa is limited to a total of 350 hours.

22. Visa is entitled to take depositions of up to three fact witnesses pursuant to FRCP
30(b)(1) from each corporate Private Plaintiff, one deposition pursuant to FRCP 30(b)(6) of each
corporate Private Plaintiff, and one deposition pursuant to FRCP 30(b)(1) of each individual
Private Plaintiff. The Government shall be entitled to examine the witness at such depositions, as
shall the Private Plaintiff that does not represent the witness. For purposes of such depositions
only, each Party is allocated examination time that shall not count against against the limits set
forth above in Paragraph 21:

a. Merchant Depositions:

1. Visa is entitled to 358 hours of non-counting time that may be used
on 30(b)(1) or 30(b)(6) depositions of merchant plaintiffs.
uu. Visa may additionally use counting hours from its budget of 350
hours should it wish to use more than 358 hours deposing merchant
plaintiffs.
ili. Visa is limited to 6 hours on the record for any single deposition.
iv. The Government is entitled to 1 non-counting hour at every

deposition taken by Visa.
V.

Vi.

Where Visa and the Government finish the merchant deposition in
under 7 hours on the record, Cardholder Plaintiffs may use up to two
hours of (counting) time to depose the witness, even where they
have not noticed or cross-noticed that deposition. The use of such
time may not extend the deposition over 7 hours total on the record.
If a Visa deposition is cross-noticed, the parties will discuss in good
faith whether a 1-day or 2-day deposition will be required. If the
parties determine that 2 days are required, the deponent has the right

to insist that the days be consecutive.

b. Cardholder Depositions:

il.

Visa is entitled to 3.5 non-counting hours per cardholder plaintiff.
Visa may additionally use its hours from its budget of 350 hours
should it wish to use additional hours deposing any cardholder
plaintiff.

The Government is entitled to 1 non-counting hour at every
cardholder deposition taken by Visa.

Where Visa and the Government finish the deposition in under 7
hours on the record, Merchant Plaintiffs may use up to two hours of
(counting) time to depose the witness, even where they have not
noticed or cross-noticed that deposition.

In no event will any cardholder plaintiff be subject to a deposition

of more than 7 hours total on the record.
c. All parties retain the right to seek changes or exceptions to these terms for good
cause.

23. Each of the Government and Visa may use a maximum of 225 hours of such
deposition time on the record in deposing adverse Party witnesses in the DOJ Action.

24. The Parties agree that the following depositions do not count against the deposition
limits: (a) depositions of the Parties’ expert witnesses; and (b) pre-complaint depositions taken in
response to Civil Investigative Demands in the Government’s related investigation.

25. Except to the extent the Parties agree otherwise, depositions taken for the sole
purpose of establishing the location, authenticity, or admissibility of documents produced by any
Party or non-party shall count against the deposition limits set forth above.

26. Reasonable breaks will be excluded from calculation of deposition time under
FRCP 30(d)(1). Only a reasonable amount of time for a deponent to review a document tendered
for the examination will count against the FRCP 30(d)(1) limits. For the avoidance of doubt, this
provision applies to both Party and non-party depositions.

27. The Parties reserve the right to seek from the Court, with good cause, or by
agreement of the Parties, additional deposition time with a particular witness or a different
allocation of time for the witness’s deposition than the allocations that are set forth in this Protocol.

28. The Private Plaintiffs and the United States will confer regarding intra-plaintiff
hours allocations, bringing to the Court any disputes as to default allocations or procedures.

29. Should the DOJ Action settle or otherwise terminate or if the Government has
indicated that its depositions are complete before the United States has exhausted the 350 hours
allotted to it for depositions, the unused balance of deposition hours will accrue to Private

Plaintiffs.
30. The Designated Court Reporting Service, as that term is used in the Remote
Deposition Protocol, shall officially record the hours spent by each Party on the examination of
witnesses during depositions and shall provide the official time to the Parties upon request.

I. PARTY DEPOSITIONS

31. Before a Party deposition is noticed, a Party seeking to notice such a deposition
shall coordinate in good faith with the other Parties to set a mutually agreeable date and time for
the deposition and, if the deposition is to proceed in-person, a location that is convenient for the
witness. Remote depositions shall be otherwise governed by the Remote Deposition Protocol.

32. Ifa Party’s former employee is sought for deposition, the noticing Party’s counsel
shall first ask counsel for the Party believed to have formerly employed the prospective deponent
(“Employer Party”) if Employer Party’s counsel represents the former employee. Employer
Party’s counsel must inform the noticing Party’s counsel whether Employer Party’s counsel
represents the former employee within 7 days. Employer Party’s counsel must make reasonable
efforts within those 7 days to contact the former employee and ask if the former employee wants
Employer Party’s counsel to represent her or him. Employer Party’s counsel must not condition
this inquiry on the noticing Party first serving the former employee pursuant to FRCP 45. The
following provisions shall also apply:

a. If, after Employer Party’s counsel notifies the noticing Party’s counsel that
it does not represent the former employee, the former employee notifies Employer Party or
Employer Party’s counsel that the former employee wants Employer Party’s counsel to
represent her or him, Employer Party’s counsel must notify the noticing Party within 3

days.
b. If Employer Party’s counsel informs the noticing Party’s counsel that the
prospective deponent is not represented by Employer Party’s counsel, Employer Party’s
counsel shall provide the noticing Party’s counsel with the former employee’s last known
contact information and address, and the noticing Party may serve the former employee
pursuant to FRCP 45.

33. The United States or Private Plaintiffs must serve a cross-notice of deposition of an
officer or employee of Visa, if any, within 7 days of service of the original notice of deposition.

34. Parties will use their best efforts to make witnesses available for deposition at a
mutually agreeable time and location (if in-person) and without unreasonable delay.

35. | Each deposition of an officer or employee of a Party under FRCP 30(b)(1) shall
presumptively be limited to 7 hours on the record absent agreement by the Parties or a showing of
good cause to the Court. Notwithstanding this provision, for officers or employees of Visa and
former officers or employees of Visa represented by counsel for Visa that have been noticed or
cross-noticed by both the United States and Private Plaintiffs, the United States and Private
Plaintiffs may collectively choose to examine 7 such witnesses for a maximum of 10 hours total
on-the-record deposition time, which deposition shall take place over two consecutive days, except
that Visa may limit to a single 7-hour day any deposition noticed of Visa’s current Chief Executive
Officer and current Chief Financial Officer. For purposes of this provision, “current” means as of
the date the deposition notice is served.

36. | Nothing in these provisions shall limit a Party from examining during a deposition
a witness it represents (e.g., an officer or employee of the Party) for the purposes of the deposition;
the first thirty minutes of any such examination shall not count toward that Party’s allocated

examination time.

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IV. NON-PARTY DEPOSITIONS

37. Before anon-party deposition is noticed (whether it is to be taken pursuant to FRCP
30(b)(1) or 30(b)(6)), a Party seeking to notice a non-party deposition shall coordinate in good
faith with all of the other Parties and, where reasonably practicable, the non-party, to attempt to
set a mutually agreeable date and time, as well as a location that is convenient for the witness, for
the deposition. All Parties shall have the opportunity to participate in this coordination process
regardless of whether the Party noticing the deposition intends to notice it for only the DOJ Action
or Private Actions.

38. A Party, who in good faith indicates that it has not received requested documents
or data from a non-party, may request that the deposition of that non-party or an employee of that
non-party be delayed for a reasonable period of time to obtain such documents or data or, if the
document discovery issue cannot be resolved consensually, to obtain resolution by the Court. Any
such request shall not be unreasonably denied.

39. The noticing Party shall serve with any subpoena for a deposition of a non-party
copies of this Deposition Protocol, the Remote Deposition Protocol, and the operative protective
orders from both the DOJ Action and the Private Actions.

40. A Party must serve a cross-notice of deposition subpoena on a non-party, if any,
within 7 days of service of the original deposition notice.

41. Absent agreement of the Parties, the Party who serves the first notice of subpoena
shall examine the witness first. In the case of either the Government or Private Plaintiffs noticing

the deposition first, both shall examine the witness before Visa examines the witness.

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42. The following provisions shall apply for non-party depositions:

a. A noticing Party may examine a non-party witness for up to 5.5 hours if no
other Parties cross-notice the deposition, and the other Parties may examine the witness for
up to 0.75 hours each, for a total of 7 hours on the record.

b. If two Parties notice or cross-notice the deposition, then each shall be
entitled to examine the witness for up to 3.25 hours, unless the two noticing Parties agree
to different time allocations after conferring before the deposition, and the other Party may
examine the witness for up to 0.5 hours, for a total of 7 hours on the record.

C. If all Parties notice or cross-notice the deposition, then the United States
and Private Plaintiffs shall be entitled to examine the witness for up to a combined 5 hours,
and Visa may examine the witness for up to 5 hours, for a total of 10 hours on the record.

d. If either Visa, on the one hand, or the United States and Private Plaintiffs,
on the other hand, do not use the full amount of time allocated to each side, the other side
may use the remaining time, with time counted against the party that used it.

43. The United States and Private Plaintiffs may collectively choose to examine 11

non-party witnesses (whether pursuant to FRCP 30(b)(1) or 30(b)(6)) for a maximum of 7 hours

allotted between the United States and Private Plaintiffs. The Government and Private Plaintiffs

shall confer before each deposition to allocate the examination time among themselves. Visa may

also choose to examine 11 non-party witnesses for a maximum of 7 hours per deposition. For the

avoidance of doubt, these additional provisions shall apply:

a. In the event that both (a) Visa and (b) the Government and Private Plaintiffs
choose to examine the same non-party witness for up to 7 hours, the deposition of such

witness shall be no more than a total of 14 hours.

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b. In the event that only one Party chooses to examine the non-party witness
for up to 7 hours, the time allocations for cross-noticing and non-cross-noticing Parties in
Paragraph 42, supra, shall apply for the other Parties, except that the non-cross-noticing
Party in the circumstance described in Paragraph 42(b) may examine the witness for up to
1 hour.

44. The deposition of a former Party employee that is not represented by counsel for
that Party shall be considered a non-party deposition for the purposes of this Section on Non-Party
Depositions.

V. RULE 30(b)(6) DEPOSITIONS

45. Absent agreement of the Parties or order of the Court, each Party may serve one
notice pursuant to FRCP 30(b)(6) on each opposing Party. For the avoidance of doubt, Visa may
serve one notice pursuant to FRCP 30(b)(6) on each corporate entity that is a Private Plaintiff in
the Private Actions.

46. Absent agreement of the Parties or order of the Court, no more than one notice
pursuant to FRCP 30(b)(6) shall be served on a non-party by each Party. For the avoidance of
doubt, Private Plaintiffs are two Parties (Merchant Plaintiffs and Cardholder Plaintiffs) for the
purposes of this provision.

47. The United States and the Private Plaintiffs shall coordinate to serve their FRCP
30(b)(6) notices on Visa on the same date and, in any event, no more than one day apart.

48. If more than one Party intends to serve a FRCP 30(b)(6) notice on a non-party, the
Parties will confer in good faith and reasonably attempt to serve the notice(s) on the same date

and, in any event, no more than one day apart.

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49. FRCP 30(b)(6) notices may call for testimony on multiple subjects, and the
responding Party or non-party may designate one or more different witnesses as to each subject
matter. For those FRCP 30(b)(6) depositions for which the responding Party has designated
multiple witnesses, the noticing Party may elect to have a different attorney examine each
designated witness.

50. No Party shall serve a FRCP 30(b)(6) notice later than August 7, 2026. Written
responses and objections to FRCP 30(b)(6) notices shall be due 21 days after service.

51. The Party or non-party shall identify the corporate representative(s) for a FRCP
30(b)(6) deposition, and the topic(s) on which each representative will testify, no later than 2 weeks
before the date of the deposition.

52. | FRCP 30(b)(6) deposition testimony shall be limited to 21 hours total per Party or
non-party (regardless of the number of corporate designees for the Party or non-party), absent
agreement by the Parties or a showing of good cause to the Court.

53. For any deponents testifying pursuant to FRCP 30(b)(1) and 30(b)(6), the Parties
will endeavor in good faith to schedule the corporate representative and individual portions of
those depositions on the same day or on consecutive business days when reasonably practicable
(or on non-consecutive business days if that is the deponent’s preference).

54. The Parties agree that time spent on a witness’s FRCP 30(b)(6) testimony does not
count towards the hours of on-the-record FRCP 30(b)(1) testimony for that witness, and, likewise,
time spent on an individual’s FRCP 30(b)(1) testimony does not count towards the hours of on-

the-record FRCP 30(b)(6) testimony.

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VI. EXHIBITS AND DOCUMENTS

55. For in-person depositions, deposing counsel shall make reasonable efforts to
provide one physical copy of each exhibit entered or document used at a deposition to (a) the
witness, (b) counsel defending the witness, (c) the court reporter, (d) other noticing counsel, if any,
and (e) each non-noticing Party present, immediately before its use unless the exhibit’s or
document’s characteristics or other circumstances make presenting a physical copy unreasonable.

56. _In-person examining counsel shall also make available electronic copies of exhibits
entered or documents used, including Party and non-party counsel attending the deposition either
in person or remotely.

57. Except as otherwise addressed in this order, the Remote Deposition Protocol shall

govern the use of exhibits at depositions proceeding by remote means. See Remote Deposition

Protocol § VI.

VII. MOTIONS TO COMPEL SUBPOENAS FOR PURPOSES OF PROCEEDING
WITH DEPOSITIONS
58. To avoid unnecessary delay with regard to the scheduling of deposition of non-

parties, the Parties agree that, no later than two weeks after June 26, 2026, they must either move
to compel any non-party included on any preliminary witness list exchanged in the government
case that received a subpoena for documents on or before April 13, 2026 but has not yet completed
production of documents in response to that subpoena, or be deemed to have waived their right
under Paragraph 38 of this Amended Stipulation and Order to request that any deposition of that
non-party or an employee of that non-party be delayed. However, to the extent that the non-party
has already agreed, or agrees prior to June 26, 2026, to complete their productions of documents

in response to the subpoena by a date certain (no later than July 31), and is working in good faith

15
with the parties on document production, the deadline for moving to compel in the foregoing
sentence shall be extended until two weeks after that date certain deadline has passed.

59. The Parties also agree that, no later than two weeks after July 10, 2026, they must
either move to compel any non-party not included on any preliminary witness list exchanged in
the government case that received a subpoena for documents on or before April 13, 2026 but has
not yet completed production of documents in response to that subpoena, or be deemed to have
waived their right under Paragraph 38 of this Amended Stipulation and Order to request that any
deposition of that non-party or an employee of that non-party be delayed. However, to the extent
that the non-party has already agreed, or agrees prior to July 10, 2026, to complete their
productions of documents in response to the subpoena by a date certain (no later than August 14),
and is working in good faith with the parties on document production, the deadline for moving to
compel in the foregoing sentence shall be extended until two weeks after that date certain deadline
has passed.

60. The filing of a letter-motion for a premotion discovery conference pursuant to Local
Civil Rule 37.2 or the local rule of the relevant district court shall be deemed to satisfy the
foregoing deadlines for filing any motion to compel.

61. The parties retain the right to move the court to reopen a non-party deposition
should that non-party later produce additional documents after any deposition of that non-party or
any employee of that non-party.

62. The parties agree that the above deadlines pertaining to motions to compel only
affect whether a party can invoke the pendency of document discovery as a basis for postponing a
deposition of the non-party. In particular, the above deadlines do not apply to requests for

documents or data, including structured data, from non-parties that will not impact the timing of

16
non-party depositions. The parties may continue to seek documents or data from non-patties,
negotiate that documents or data be produced in response to such requests for production, and
move to compel the production of documents or data without regard to the above deadlines,
provided that if the motion to compel deadlines discussed above have passed, the pendency of
those efforts will not be a basis for postponing the deposition.

63. In order to avoid needlessly burdening the Court with an unnecessary motion to
compel, the parties agree to discuss in good faith whether an extension of the foregoing deadlines
to file a motion to compel as to a particular non-party is appropriate, given unforeseen facts of the
relevant non-party’s subpoena compliance efforts. The party negotiating with the relevant non-
party shall make all efforts to ensure that the deposition of the non-party shall be scheduled
promptly to avoid disrupting case deadlines. Any such extension to file a motion to compel may

be granted by agreement of the parties.

The Parties appreciate the Court’s consideration of this proposed order.

Dated: June 15, 2026 Respectfully Submitted,

By: /s/ Jason S. Hartley

Jason S. Hartley

HARTLEY LLP

101 W. Broadway, Suite 820
San Diego, California 92101
Telephone: (619) 400-5822
hartley@hartleyllp.com
lindner@hartleyllp.com

Joseph R. Saveri

Cadio Zirpoli

David H. Seidel

T. Brent Jordan

JOSEPH SAVERI LAW FIRM, LLP

Richard M. Paul ITI

Mary Jane Fait

Laura C. Fellows

David W. Bodenheimer
PAUL LLP

600 Broadway, Suite 600
Kansas City, Missouri 64105
Telephone: (816) 984-8100
Rick@PaulLLP.com
MaryJane@PaulLLP.com
Laura@PaulLLP.com
David@PaulLLP.com

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601 California Street, Suite 1505
San Fransico, California 94108
Telephone: (415) 500-6800
jsaveri@saverilawfirm.com
czirpoli@saverilawfirm.com
dseidel@saverilawfirm.com
tbjordan@saverilawfirm.com

Interim Co-Lead Counsel for Cardholder
Plaintiffs and the Cardholder Plaintiff
Class

/s/ Brent W. Johnson

Daniel McCuaig

Brent W. Johnson

Benjamin D. Brown

Zachary Krowitz

COHEN MILSTEIN SELLERS & TOLL
PLLC

1100 New York Ave. NW e Eighth Floor
Washington, DC 20005

(202) 408-4600
dmccuaig@cohenmilstein.com
bjohnson@cohenmilstein.com
bbrown@cohenmilstein.com
zkrowitz@cohenmilstein.com

Manuel J. Dominguez

COHEN MILSTEIN SELLERS & TOLL
PLLC

2925 PGA Blvd. e Suite 200 Palm

Beach Gardens, FL 33410

(561) 515-2604
jdominguez@cohenmilstein.com

Christopher J Cormier

Matt Strauser

Ian Baize

BURNS CHAREST LLP

4725 Wisconsin Avenue, NW, Suite 200
Washington, DC 20016

(202) 577-3977
ccormier@burnscharest.com
mstrauser@burnscharest.com
ibaize@pburnscharest.com

Christopher J. Hydal

JOSEPH SAVERI LAW FIRM, LLP
40 Worth Street, Suite 602

New York, New York 10013
Telephone: (646) 527-7310
chydal@saverilawfirm.com

Daniel P. Weick
HAUSFELD LLP

33 Whitehall Street 14th Floor
New York, NY 10004

Tel: (646) 357-1100

Fax: (212) 202-4322
dweick@hausfeld.com

Jane Shin

HAUSFELD LLP

1200 17th Street, NW Suite 600
Washington, DC 20036

Tel: (202) 540-7200

Fax: (202) 540-7201
jshin@hausfeld.com

Brian Danitz

Adam J. Zapala
COTCHETT, PITRE & McCARTHY, LLP
840 Malcolm Road
Burlingame, CA 94010

T: (650) 697-6000

F: (650) 697-0577

40 Worth Street, Suite 602
New York, NY 10013

T: (212) 381-6373

F: (917) 398-7753
bdanitz@cpmlegal.com
azapala@cpmlegal.com

18
Matthew Tripolitsiotis

BURNS CHAREST LLP

757 Third Avenue, 20% Floor
New York, NY 10017

(469) 895-5269

Interim Co-Lead and Executive Committee

Counsel for Merchant Plaintiffs and the
Merchant Plaintiff Class

/s/ Michele Trichler

Craig Conrath

Bennett J. Matelson

Erin Murdock-Park

Michele Trichler

United States Department of Justice
Antitrust Division

450 Fifth Street, N.W., Suite 4000
Telephone: (202) 894-4266
Facsimile: (202) 514-7308
Craig.Conrath@usdoj.gov
Bennett.Matelson@usdoj.gov
Erin.Murdock-Park@usdoj.gov
Michele.Trichler@usdo}j.gov

Counsel for Plaintiff, the United States

WILKINSON STEKLOFF LLP

/s/ Kieran Gostin

Kieran Gostin (SBN NY 4847653)

Beth Wilkinson (SBN NY 2181592)
Brian Stekloff (admitted pro hac vice)
Kosta Stojilkovic (admitted pro hac vice)
Roxana Guidero (admitted pro hac vice)
Alysha Bohanon (admitted pro hac vice)
2001 M Street NW, 10th Floor
Washington, DC 20036

Telephone: (202) 847-4000

Facsimile: (202) 847-4005
kgostin@wilkinsonstekloff.com

19
bwilkinson@wilkinsonstekloff.com
bstekloff@wilkinsonstekloff.com
kstojilkovic@wilkinsonstekloff.com
rguidero@wilkinsonstekloff.com
abohanon@wilkinsonstekloff.com

Jeremy S. Barber (SBN NY 5344304)
130 W 42nd Street, Floor 24

New York, NY 10036

Tel. (212) 294-8910

Fac. (202) 847-4005
jbarber@wilkinsonstekloff.com

ARNOLD & PORTER KAYE SCHOLER
LLP

Margaret A. Rogers (SBN NY 4647087)
250 West 55th Street

New York, NY 10019

Tel. (212) 836-8000
margaret.rogers@arnoldporter.com

Anne P. Davis (admitted pro hac vice)
Robert Katerberg (admitted pro hac vice)
601 Massachusetts Avenue NW
Washington, D.C. 20001

Tel. (202) 942-5000
anne.davis@arnoldporter.com
robert.katerberg@arnoldporter.com

Counsel for Defendant Visa Inc.

Cll het

20


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