Coleman, et al v. Schwarzenegger, et al

Filing 7965

ORDER signed by Chief District Judge Kimberly J. Mueller on 9/26/2023 PROVIDING notice that the court intends to appoint Dwight Steward, Ph.D., Principal Economist of EmployStats, as a technical advisor. The parties will bear the cost of the adviso r's $725 per hour rate plus reasonable expenses. Within 14 days from the date of this order the parties shall meet and confer to determine how these costs shall be apportioned. If either plaintiffs or defendants object to Dr. Steward's appointment, they will inform the court by noon on 9/28/2023. (Huang, H)

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 1 of 51
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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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RALPH COLEMAN, et al.,

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No. 2:90-cv-0520 KJM DB P

Plaintiffs,

ORDER

v.
GAVIN NEWSOM, et al.,
Defendants.

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After review of the parties’ opening trial briefs, the court finds it necessary to appoint a

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technical advisor to assist it in properly understanding certain issues related to labor economics

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the parties will raise during the upcoming enforcement proceedings. This order is to provide

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notice that the court intends to appoint Dwight Steward, Ph.D., Principal Economist of

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EmployStats, as a technical advisor for this purpose.

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The court has inherent authority to appoint a technical advisor “[w]hen outside technical

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expertise case be helpful” to it. Federal Trade Com’n v. Enforma Natural Products, Inc. (“FTC

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v. Enforma”), 362 F.3d 1204, 1213 (9th Cir. 2004) (citing Association of Mexican-American

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Educators v. State of California (“AAME”), 231 F.3d 572, 590 (9th Cir. 2000))

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The role of a technical advisor is to organize, advise on, and help the court
understand relevant scientific evidence. [citation omitted] A technical advisor is a
tutor who aids the court in understanding the “jargon and theory” relevant to the
technical aspects of the evidence. Reilly v. United States, 863 F.2d 149, 158 (1st Cir.
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1988). A technical advisor may not assume the role of an expert witness by
supplying new evidence; nor may an advisor usurp the role of the judge by making
findings of fact or conclusions of law. See A & M Records, Inc. v. Napster, Inc.,
284 F.3d 1091, 1097 (9th Cir. 2002); Reilly, 863 F.2d at 155.

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FTC v. Enforma, id. “Technical advisors, acting as such, are not subject to the provisions of Rule

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706, which govern court-appointed expert witnesses.” Id. (citing AMAE, 231 F.3d at 591; Reilly,

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863 F.2d at 156-57)) (emphasis in original).

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In his role as technical advisor, Dr. Steward will not offer expert testimony, nor will he
provide his opinion on how the court should rule on the issues raised in the upcoming

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proceedings. Rather, Dr. Steward will assist the court in a tutorial format by responding to the

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court’s questions about terminology and methodologies used by labor economists as well as

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issues raised by the reports and testimony of the parties’ experts’, so that the court may better

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evaluate the evidence. In doing so, Dr. Steward will be permitted to have ex parte

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communications with the court. The court will report to the parties on its discussions with

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Dr. Steward.

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The court previously authorized the Special Master to appoint Dr. Steward to his team “to

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conduct labor market and salary analyses in an effort ‘to determine the potential efficacy of . . .

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collective bargaining salary and compensation increases’ as part of an overall effort to bring

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defendants into compliance with required mental health staffing levels.’” September 11, 2018

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Order, ECF No. 5919 at 2. The court never identified Dr. Steward as an expert witness. Id. at 3.

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With the concurrence of the parties, the court ultimately decided to note the presence of

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Dr. Steward’s report, ECF No. 6695, in the record as “a tool available to the parties,” without

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resolving any objections to it. Reporter’s Transcript of Proceedings (RT 5/14/21), ECF No. 7180,

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at 44-46; see also ECF No. 7162. The court will not rely on Dr. Steward’s report in connection

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with the upcoming proceedings. As confirmation of his professional credentials, a copy of

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Dr. Steward’s curriculum vita is attached to this order as Exhibit A.

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The parties will bear the cost of the advisor’s $725 per hour rate plus reasonable

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expenses. Within fourteen days from the date of this order the parties shall meet and confer to

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determine how these costs shall be apportioned consistent with their practice in
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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 3 of 51
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applying the standard for payments of plaintiffs’ fees and costs by defendants, set out

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in the periodic fees process in this case. See March 20, 1996 Stipulation and Order, ECF No. 673.

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If either plaintiffs or defendants object to Dr. Steward’s appointment, they will inform the
court by noon on Thursday, September 28, 2023.
IT IS SO ORDERED.
DATED: September 26, 2023.

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 4 of 51
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EXHIBIT A

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 5 of 51

Curriculum Vita
Dwight Steward, Ph.D.

Dr. Steward is an economist and principal of EmployStats.
EmployStats is a boutique economic consulting firm that
provides economic research and expert witness services to
legal, government, and business communities nationwide.
EmployStats specializes in large data analysis projects involving
wage and hour and employment class action lawsuits, injury and
death litigation, consumer mass torts, and commercial lawsuits.
EmployStats has been successfully in business since 1997 and
has offices in Austin, Texas and San Mateo, California.
Dr. Steward has provided consultation, expert reports and testimony in hundreds of cases
nationwide. He has provided testimony on issues involving mitigation and economic damages
in employment lawsuits, wage and hour and FLSA liability and damages, statistical analysis of
discrimination, and economic damages of individuals and businesses.
Dr. Steward is an active community member and serves in a number of leadership positions.
He is currently on the Board of Directors of The Boys and Girls Club of Austin and serves as the
Midwest Vice President of the National Association of Forensic Economics. He is also a
member of the Texas A&M University Statewide Police Racial Profiling Task Force and an
former President of the University of Texas at Austin Army ROTC Alumni Association.
Dr. Steward is the author of three professional economics textbooks and was previously a
Senior Lecturer in the Economics department at The University of Texas at Austin and was a
Visiting Assistant Professor in the Finance Department in the College of Business at Sam
Houston State University in Huntsville, Texas. He served stateside in the U.S. Army as an Field
Artillery Officer during Operation Desert Storm and in the U.S. Army Reserves. He obtained the
rank of 1st Lt. and received an honorable discharge following the completion of his service.
Dr. Steward holds a Ph.D. in Economics from the University of Iowa, and a B.A. in Economics
from the University of Texas at Austin. He completed his K-12 schooling in San Antonio, Texas.

www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 6 of 51

Presentations and Public Speaking Engagements
(Updated August 18, 2023)
WEAI Annual Conference, "NAFE Session 2: The Reference Guide - A Panel Discussion",
San Diego, California, July 3rd, 2023.
AREA Annual Conference, "Analyzing Employment Termination Damages in Special
Cases: A View from Plaintiff and Defense Perspectives", Reno, Nevada, May 19, 2023.
ABA Employment Rights and Responsibilities Midwinter Meeting, "Use of Experts in
Class/Collective Litigation", Rancho Mirage, California, March 14, 2023.

15th Annual ABA Section of Labor and Employment Law Conference, "Wage and Hour
Fundamentals", Virtual Conference, November 10, 2021.

Western Economic Association International 96th Annual Conference, “NAFE Session:
Mitigation in Employment Cases”, Virtual Conference, June 27, 2021.

National Employment Lawyers Association’s (NELA’s) 2020 Virtual Convention, “When To
Use Experts In Employment Cases”, Online (Virtual Panel), July 10, 2020.

Practising Law Institute (PLI) Wage & Hour Litigation and Compliance 2020, “Calculating
Time Worked and Damages in Wage & Hour Cases”, New York, New York, January 28,
2020

Western Economic Association International 94th Annual Conference, “NAFE Session 1:
Statistical, Survey, And Data Issues In Wage And Hour Cases”, San Francisco, California,
June 29, 2019
Professional Liability Underwriting Society (PLUS) Hartford Chapter EPLI Seminar,
www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 7 of 51

“#MeToo, Pay Equity and ‘What’s Behind Door #3’ - Taking the Mystery and Misery Out of
Damages in Employment Matters”, June 6, 2019
National Employment Lawyers Association Spring Seminar, Epic Advocacy: Protecting
Wages In Litigation & Arbitration, “Calculating Damages: Views From An Expert, An FRE
1006 Summary Witness, And Lawyers”, Denver, Colorado, April 13, 2019
University of Baltimore Big Data CLE Seminar, “Data Analytics in Complex Litigation”,
Baltimore, Maryland, April 5, 2019
American Economics Association Annual Meeting, “Stationarity Tests and Margin of Error in
Forensic Economics”, Atlanta, Georgia, January 4, 2019
Economics/Liberal Arts Career Forum at The University of Texas, Austin, Texas, November
2, 2018
Employment Law CLE Seminar, “Surveys in Class Action Wage and Hour Cases”, San
Francisco, California, October 3, 2018
Employment Law CLE Seminar, “California Fair Pay Act”, San Francisco, California,
October 16, 2017
Eastern Economics Association Conference, “Risk Shifting by Employee Terminations and
Layoffs”, Discussant, New York City February 2017
American Economics Association Annual Meeting, “Pitfalls of Forensic Economic Analysis:
Employment”, San Francisco, California, January 3, 2016
Eastern Economics Association Conference, “Extending the Econometric Model of Worklife
Expectancy”, New York, New York, February 27, 2015

Employment Law CLE, “What is wrong with this paycheck? Investigating allegations of
FSLA and wage and hour violations using payroll, time and personnel records”, San
www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 8 of 51

Francisco, California, March 6, 2014

Employment Law CLE, “What is wrong with this paycheck? Investigating allegations of
FSLA and wage and hour violations using payroll, time and personnel records”, Oakland,
California, March 5, 2014

Employment Law CLE, “What is wrong with this paycheck? Investigating allegations of
FSLA and wage and hour violations using payroll, time and personnel records”, Century
City, California, January 30, 2014

Fulbright & Jaworski LLP, “Use of Economic Experts in Employment Litigation”, Houston,
Texas, April 18, 2013

Southern Economic Association Conference, “Economic Damage Valuations in South
Africa”, New Orleans, Louisiana, November 17, 2012

Houston Bar Association, Employment Section “Back Pay and Front Pay Calculations in
Employment Termination”, Houston, Texas, March 12, 2012

Allied Social Science Association Conference, Forensic Economics II “Household Services
Production in Mexico”, Chicago, Illinois, January 7, 2012

Texas Labor & Employee Relations Consortium hosted by CenterPoint Energy, “Employee
Labor Unions and EEO Compliance”, Houston, Texas, June 9, 2011

Allied Social Science Association Conference, “Using Economic, Statistical and Time Clock
Evidence in Wage and Hour and Employment Lawsuits”, Chicago, Illinois, April 2011

Employment Law CLE, “Using Economic, Statistical and Time Clock Evidence in Wage and
Hour and Employment Lawsuits”, San Francisco, California, March 4, 2011
www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 9 of 51

Southern Economic Association Conference, “Calculating Economic Damages for
Previously Incarcerated Individuals”, Atlanta, Georgia, November 21, 2010

Employment Law CLE, “Using Economic, Statistical and Time Clock Evidence in Wage and
Hour and Employment Lawsuits”, Houston, Texas, October 21, 2010

Dallas Bar Association’s Friday Clinic, “Valuing Economic Damages in Injury, Wrongful
Death and Employment Cases”, Dallas, Texas, September 10, 2010

American Association of Justice Annual Convention, “Evaluating Damages for the Incarcerated”,
Vancouver, Canada, July 2010
Academy of Economics and Finance, 37th Annual Meetings, “Valuing Employee Stock Options in
a Breach of Contract Case”, Houston, Texas, February 2010
American Economic Association Meetings, “Valuing Employee Stock Options in a Breach of
Contract Case”, Atlanta, Georgia, January 2010
Capital Area Paralegal Association CLE, “Valuing Economic Damages in Injury, Wrongful Death
and Employment Cases”, Austin, Texas, October 28, 2009

UT CLE, The 15th Annual Labor and Employment Law Conference, Austin, Texas, May 29 - 30,
2008
NAACP 71st Texas Annual meeting, “Police Use of Force and Racial Profiling Panel Discussion”,
McAllen, Texas, October 12, 2007
Western Economic Association International, Chairperson of Employment Discrimination and
Wage and Hour Analysis Sessions, Seattle, Washington, June 29 – July 1, 2007

www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 10 of 51

UT School of Law 14th Annual Employment Law CLE, Presented with Stephanie Botello,
“Calculating, Proving, and Mitigating Damages Involving Re-employment”, Austin, Texas, May
17, 2007
Iowa Economic Alumni Workshop, Tippie College of Business, “How Long do Mexican Migrants
Work in the U.S.?”, Iowa City, Iowa, April 21, 2007
Trialsmith CLE webinar series, “Calculating Economic Damages in Injury and Death Cases”,
February 8, 2007
American Economic Association Annual Meeting, Session Chairperson, “Economic Issues in
Estimating Damages in Commercial and Personal Injury Cases”, Chicago, Illinois, January 6,
2007
MADD National Diversity Forum II, speaker for “Profiling to Behavior” a moderated panel
discussion, Dallas, Texas, May 16 – 18, 2006
Academy of Economics and Finance Meeting, “Valuing Employee Stock Option Grants in
Litigation”, Houston, Texas, February 10, 2006

American Economic Association Annual Meeting, “Estimating the Work Life Expectancy of
Undocumented Mexican Migrant Workers”, Boston, Massachusetts, January 2006
DRI 2005 Annual Meeting, speaker for employment law “Lies, Damn Lies, and Employment
Statistics”, Chicago, Illinois, October 21, 2005

Labor and Employment Roundtable, sponsored by Texas Lawyer, August 31, 2005
Austin Business District Roundtable, ‘Economic Roundtable on the Future of the Austin and
Texas Economy”, July, 2005

www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 11 of 51

Iowa Alumni Workshop, Department of Economics, Tippie College of Business: “Economics and
Economists in the U.S. Legal System: A View from the Trenches”, University of Iowa, April, 2005
Police Executive Research Forum: “Data Analysis Guidelines for Poststop Analyses”, Las Vegas
and Kansas City; 2004
Texas State Capitol Media Press Conference – Study Release, “An Examination of Consent
Searches and Contraband Hit Rates at Texas Traffic Stops”, Austin, Texas, 2005

Police Executive Research Forum, Racial Profiling Meeting: Denominator Conference, “Use of
Census Data to Measure Racial Disparities in Traffic Stops”, Las Vegas, Nevada, 2004
Austin City Council Meeting, West University Area Rezoning, “Rezoning Austin’s West Campus,
A Unique Opportunity for Smart Growth”, Austin, Texas, 2004
African-American Economic Legislative Forum, Hosted by Representative Senfronia Thompson,
Roundtable Speaker, Texas State Capitol, Austin, Texas, 2004
North Texas Police Racial Profiling Conference, The University of Texas at Arlington, Center for
Mexican American Studies, “The 2002 Racial Profiling Data Revisited: A Look to the Future”,
Arlington, Texas 2004

NAACP and LULAC Police - Community Town Hall Meeting, “A Look at Police Racial

Profiling Statistics in Fort Worth, Fort Worth, Texas, 2004
NAACP and LULAC Police - Community Town Hall Meeting, “A Look at Police Racial Profiling
Statistics in Beaumont, Beaumont, Texas, 2004

www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 12 of 51

NAACP and LULAC Police - Community Town Hall Meeting, “A Look at Police Racial Profiling
Statistics in Houston, Houston, Texas, 2004
Texas State Capitol, Senator Royce West Legislative Roundtable of Police Racial Profiling Data
Collection and SB 1074, Roundtable Speaker, Austin, Texas, 2004
Police - Community Relation Forum, “A Preliminary Look at Racial Profiling in Texas and the
Huntsville Area”, Huntsville, Texas, 2003
Economic Issues in the African-American Forum, “The Roots of African-American Economic
Progress”, Radio Program, KAZI, Austin, Texas 2003
Texas State Bar Advanced Employment Law CLE Seminar, “Lies, Damn Lies, and Statistics”,
Houston, Texas, 2003
Haynes and Boone, LLP, “Use and [Misuse] of Economics in Economic Damage Calculations”,
Austin, Texas, 2002
Texas Police Chief Forum on Racial Profiling, “Using Search Data and Stop Data to Measure
Racial Profiling”, University of Texas at Austin, Austin, Texas, 2002
Texas State Capitol Press Conference - Study Release, “Selecting Racially Balanced Texas
Juries”, Austin, Texas, 2003
Texas State Capitol, Press Conference-Study Release, “Cost savings and Efficiency in the Texas
State Criminal Justice System”, Austin, Texas, 2003

PowerCenter, “Drug treatment programs and Cost Savings in Texas”, Houston, Texas, 2003
Texas State Senate Chambers, “Statistical Analysis of Police Racial Profiling Data”, Austin,
Texas 2001

www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 13 of 51

This Week with Senator West, Television show, Roundtable Discussion, Topic: “Detecting Racial
Profiling”, Austin, Texas 2001
Texas State Capitol, Media Press Conference, “Release of NAACP Police Racial Profiling
Study”, Austin, Texas, 2000
College of Business Administration, Sam Houston State University, “Lending Discrimination”,
Huntsville, Texas 1998
Federal Reserve Bank of Chicago; Moderator, “Detecting Lending Discrimination in Credit
Markets”, Chicago, Illinois, 1997
Federal Reserve Board, “Bank Mergers and Managerial Efficiency”, Washington D.C, 1995

www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 14 of 51

Writing and Publications
(Updated January 28, 2022)
"Economic Losses and Mitigation after an Employment Termination", Palgrave Macmillan,
January 2022

“Big Data Analytics in U.S. Courts: Uses, Challenges, and Implications”, Palgrave Pivot
Publishing, December 2019
“Statistical Analysis of Employment Data in Discrimination Lawsuits and EEO Audits: A
statistical guide for attorneys, human resource professionals and EEO compliance
personnel”, Econometrics Publishing, February 2010
“Back Pay and Front Pay Calculations in Employment Termination Cases: Accounting for
re-employment and mitigation efforts” (Joint with Stephanie Botello, Ph.D.), 2008, available
at Social Science Research Network
“Economic Damages Primer for Attorneys: The building blocks for valuing economic
damages in personal injury, wrongful death, medical malpractice, and products liability
cases”, (Joint with Charles Mahla, Ph.D., Michael Sadler, Ph.D., Chad Shirley, Ph.D., Doug
Berg, Ph.D., et al.), Econ One Research, Inc., September 2007
"How Long do Mexican Migrants Work in the U.S.?" (Joint with Amy Raub and Jeannie
Elliott), Journal of Forensic Economics, Volume XIX No. 2
“Evaluating the Statistical and Economic Significance of Statistical Evidence in Employment
Discrimination Cases, Expert Evidence Report”, The Bureau of National Affairs, Inc., Vol. 5,
No. 5; p. 117-119; March 7, 2005 and March 23, 2005
“Racial Differences in Interest Rates”, Midwestern Business and Economic Review, p. 9 –
24, Number 34, Fall 2004

www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 15 of 51

“Lies, Damn Lies, and Statistics: A View from a Statistical Expert”, Texas State Bar
Advanced Employment Law CLE Chapter 13.1, 2003
“Evaluating Statistical Evidence in Employment Discrimination Cases”, Expert Evidence
Report, Bureau of National Affairs, p. 117-119.
“An Examination of Consent Searches and Contraband Hit Rates at Texas Traffic Stops”,
(Co-Authored) Technical Report Prepared for NAACP, LULAC, and Texas Criminal Justice
Reform Coalition 2005
“Racial Profiling: Texas Traffic Stops and Searches; A first look at the nation’s most
comprehensive racial profiling dataset”, (Co-Authored) Technical Report Prepared for
NAACP, LULAC, and Texas Criminal Justice Reform Coalition, 2004
“Re-Zoning Austin’s West Campus: A Unique Opportunity for Smart Growth”, Technical
Report Prepared for the University Area Partners, 2004
“Drug Treatment Programs and Cost Savings in the Texas State Criminal Justice System”,
Technical Report Prepared for Justice Policy Institute and NAACP Voter Fund, 2003
“A Statistical Methodology to Help Courts Select Racially Balanced Texas Juries”, Technical
Report Prepared for the NAACP, 2003
“A Re-examination of Police Racial Profiling Using the Becker Model of Discrimination”,
co-authors Doug Berg and John Maroney, Working paper, 2002
“A Fixed-Effects Discrete Choice Model of Racial Profiling in Police Vehicle Searches”,
Working Paper, 2002
“A Preliminary Examination of Racial Profiling in Texas: A look at Police Search Rates in
Texas”, (Co-Authored), Technical Report Prepared for the NAACP, 2000
“A Note: Bootstrap Standard Errors and Confidence Intervals for Weak Axiom of Cost
Minimization (WACM) Based Managerial Efficiency Estimates”, Published Applied

www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 16 of 51

Economics Letters V.2., 1998
“Bank Mergers and Cost Efficiency”, Ph.D. Dissertation, University of Iowa, 1995
“Racial Differences in Interest Rates: A Cluster Analysis Approach”, Co-authors Doug Berg
and Donald Bumpass (SHSU) (2002), Paper accepted for presentation at Economics and
Finance Association, February 2003 meeting in Savannah, Georgia.

www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 17 of 51

Expert Witness Testimony
(updated August 18, 2023)
Lianna Shakhnazarian v. Freedman and Taitelman LLP, Bryan Freedman, Patricia Arias
Musitano, In the Superior Court of the State of California - County of Los Angeles;
deposition testimony, August 2023.
Robert L. Cabes, Jr. v. Intrepid Financial Partners, LLC before the American Arbitration
Association, Houston, Texas; arbitration testimony, April 2023.
Hasan Gokal v. Harris County, Texas d/b/a Harris County Public Health, In the District Court
of Harris County, Texas 333rd Judicial District; deposition testimony, March 2023.

Luke Adelman, Elizabeth Anderson, Ellesse Anderson, Jeffrey Bellows, Katherine Butler,
Cheyenne Chitry, Christina Denton, Jacqueline Foster, James Hancock, Donnie Hyso,
Casey McKay, Hannah Rothschild, Cassandra Sweeney, and Michael Whiter, individually
and on behalf of all others similarly situated v. Starbucks Corporation, In the United States
District Court, Northern District of California - San Francisco Division; deposition testimony,
February 2023.
Laura Munoz v. Monterey Mushrooms, Inc., Gomelia Nacianceno and Armando Juarez, In
the District Court of Madison County, Texas 12th Judicial District; deposition testimony,
January, 2023.
Briana Ribota; Nicole Sylvestre; Lasha Dalton; and Yolanda Salazar, individually and on
behalf of all others similarly situated v. County of San Bernardino, a legal subdivision of the
State of California, and DOES 1-10, inclusive, In the United States District Court, Central
District of California - Eastern Division; deposition testimony, December 2022.
Alma Mateos, and individual, on behalf of herself and all other similarly situated v.
Millennium Products, Inc., a California Corporation; and DOES 1 through 10, inclusive, In
the Superior Court of the State of California - County of Los Angeles; deposition testimony,
www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 18 of 51

November 2022.
Mark Treadwell v. Chicago Police Officers David Salgado (#16347), Xavier Elizondo
(#1340), and the City of Chicago, Illinois, In the United States District Court For The
Northern District of Illinois - Eastern Division; deposition testimony, October 2022.
Equal Employment Opportunity Commission v. Hiland Dairy Foods Company, LLC, In the
United States District Court For The Western District District of Oklahoma; deposition
testimony, July 2022.
Charles H. Newman III, and James F. Lawler, Jr. v. Beadles, Newman & Lawler, A
Professional Corporation, American Document Systems, LLC, Dudley D. Beadles, and
John F. Beadles, In the United States District Court of Tarrant County, Texas 96th Judicial
District; deposition testimony, May 2022.
Nancy Kinney, Charles Townsley, Michael Sauro, Walter Noffsinger, Rosa Davidson,
Michael Kelly, Tom Kierl, Constance Lewis, Sheri Parr, Paul Pham, Alvaro Paiz, Titon
Hoque, Chris Mancuso, Wilbert Talmadge, Janet Gelphman, Thanh Do v. International
Business Machines Corporation, In the United States District Court for the Western Division
of Texas - Austin Division; deposition testimony, May 2022.
Jeremy Sorenson, an individual, Randal Reep, an individual, Randal Smith, an individual,
Adam McLean, an individual, James Doyle, an individual on behalf of other persons
similarly situated v. Delta Air Lines, Inc., a Delaware Corporation, In the United States
District Court for the Northern District of Georgia - Atlanta Division; deposition testimony,
December 2021.
Abel Cantaro Castillo, and those similarly situated v. Western Range Association, In the
United States District Court for the District of Nevada; deposition testimony, November
2021.

Briana Ribota; Nicoale Sylvestre; Lasha Dalton; and Yolanda Salazar, individually and on
behalf of all other similarly situated v. County of San Bernardino, a legal subdivision of the
State of California, and DOES 1-10, inclusive, In the United States District Court for the
Central District of California - Eastern Division; deposition testimony, October 2021.
www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 19 of 51

Dr. Rosandra Daywalker v. University of Texas Medical Branch at Galveston and Dr. Ben G.
Raimer, in his Official Capacity, In the United States District Court for the Southern District
of Texas Galveston Division; deposition testimony, September 2021.
Luis Martinez Munoz v. United Rentals North America, Inc. and Juan Flores, In the District
Court of Travis County, Texas 419th Judicial District; deposition testimony, August 2021.

Nicholas Cordell Larsen v. Litania Sports Group, Inc., and University Interscholastic
League, In the District Court of Travis County, Texas 250th Judicial District; deposition
testimony, August 2021.

Farhad Shahrokhi v. The University of North Texas, In the United States District Court for
the Eastern District of Texas Sherman Division; deposition testimony, June 2021.
Kristal Nucci and Kelly Shaw, individually and on behalf of all others similarly situated and
the California Labor & Workforce Development Agency, and ANA Goswick, individually and
on behalf of all others similarly situated v. Rite Aid Corporation, Thrifty Payless, Inc. and
Does 1-10, inclusive, United States District Court Northern District of California; deposition
testimony, June 2021.
Gabriela Balderas, Individually, and as Personal Representative of the Estate of Damian
Salinas, Deceased and as Next Friend of Angel Salinas and Brandon Salinas, Minors v.
Manuel Bugarin D/B/A MB Brokers and Sanderson Farms, Inc., In The District Court of
McLennan County, Texas 170th Judicial District; deposition testimony, April 2021.
David Heller v. Uber Technologies Inc., Uber Canada, Inc., Uber B.V., Rasier Operations
B.V., and Uber Portier B.V., In the Ontario Superior Court of Justice, Canada; deposition
testimony, April 2021.

Thomas Devenport v. Champion Cooler Corporation, In the District Court of Grayson
County, Texas 397th Judicial District; trial testimony, March 2021.

www.employstats.com
Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 20 of 51

Eric Ayala and Adrian Aviles, on behalf of themselves and all others similarly situated v.
UPS Supply Chain Solutions, Inc., a Delaware corporation; UPS Supply Chain Solutions
General Services, Inc., a Delaware corporation; and Does 1-10, inclusive, In the United
States District Court, Central District Of California; deposition testimony, February 2021.
Kamelia Dianati v. Baton Holding, LLC F/K/A Bankrate, Inc., and Samuel Bagot, In the
District Court of 345th Judicial District Travis County, Texas; deposition testimony,
December 2020. Cause No. D-1-GN-19-001710
Sephora Wage and Hour Cases, In the Superior Court of California for the County of San
Francisco; deposition testimony, July 2020. Case No. CJC-16-004911

Arden Rutta, individually and as Executrix of the estate of James Rutta, deceased, and
Christi Young, individually and as wrongful death beneficiary of James Rutta v. J-W Power
Company, Jamex Inc. and Texline Energy, LLC, In the District Court of Dallas County, TX
192nd Judicial District; deposition testimony, March 2020. Cause No. DC-18-00205
Ronnie Villaneueva v. Juan Fernandez, Roberto Verduzco, and the Cincinnati Insurance
Company, In the District Court of Maverick County, Texas 293rd Judicial District; trial
testimony, January 2020. Cause No. 18-10-36490-MCV
James Meek v. Equinor US Operations LLC, successor in interest to Statoil Gulf Services
LLC, In the District Court of Harris County, Texas 269th Judicial District; deposition
testimony, October 2019. Cause No. 2018-35054
Allison Spruill v. Daniel Fortes, M.D., Cardiothoracic and Vascular Surgeons, P.A., John
Williams, M.D., and Austin Radiological Associates, In the District Court of Travis County,
Texas 261st Judicial District; deposition testimony, September 2019. Cause No.
D-1-GN-17-001349

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John David Donahey III v. Progressive County Mutual Insurance Company and Federal
Insurance Company, In the District Court of Travis County, Texas 459th Judicial District;
deposition testimony, September 2019. Cause No. D-1-GN-17-006093
Juan Ramiro Perez v. Communities In Schools, In the District Court of Cameron County,
Texas 107th Judicial District; trial testimony, September 2019. Cause No. 2018-DCL-03830

United States of America v. City of Houston, United States District Court for the Southern
District of Texas Houston Division; deposition testimony, July 2019. Civil Action No.
4:18-cv-00644
Nicole Perkins and Thomas Perkins, Individuals, and Anastasia Perkins, a minor who sues
by and through her Parents and Next Friends, Nicole Perkins and Thomas Perkins v.
James Allen Newton, M.D., An Individual; Lynn Keith Whittington, M.D., an Individual;
Alabama Neonatal Medicine, P.C., a Corporation, et al., In the Circuit Court for Montgomery
County, Alabama; deposition testimony, July 2019. Civil Action No. 201899342
Jonathan Langley v. International Business Machines Corporation, United States District
Court for the Western District of Texas; deposition testimony, July 2019. Civil Action No.
1-18-cv-443
Debra Deluna, Individually and as Personal Representative of the Estate of Joseph Deluna,
Deceased; and Ashton Thorn, as Legal Guardian of Tena Aubrey Deluna, minor v.
Espinoza Stone, Inc., Espinoza Stone, Inc. DBA ESI Trucking, Jose J. Espinoza, Gabriel
Hernandez and John and Jane Does 1-10, District Court of Williamson County, Texas 425th
Judicial District; deposition testimony, June 2019. Cause No. 17-1249-C425
Doug Boram and Monica Boram, Individually and As Next Friends of Bryce Boram, a minor
v. Tara A. Mills, MD, Renaissance Women’s Group P.A., and St. David’s Healthcare
Partnership, L.P., LLP, d/b/a St. David’s North Austin Medical Center, 98th Judicial District
Court of Travis County, Texas; deposition testimony, May 2019. Cause No.
D-1-GN-12-001699

Michael Gomez and Nora Gomez v. David A. Nation, M.D., and Cardiothoracic and
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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 22 of 51

Vascular Surgeons, P.A., District Court Travis County, Texas 200th Judicial District;
deposition testimony, April 2019. Cause No. D-1-GN-18-001895
Karen Miniex v. Houston Housing Authority, United States District Court for the Southern
District of Texas Houston Division; trial testimony, March 2019. Civil Action No.
4:17-CV-00624
Estela Ruiz, individually and on Behalf of All Other Similarly Situated Employees of
Defendants v. Jack in the Box, Inc; Yadav Enterprises, Inc. (fka JIB Management, Inc.);
Parivar, Inc.; Akkam, Inc.; Amanat, Inc.; Anil Yadav; Av, Inc.; Nor-Cal Venture Group, Inc.;
Resham, Inc.; Reshiv, Inc.; Vanil, Inc.; Vanmel, Inc.; Vansh, Inc.; Varris management, Inc.;
Yadav, Inc.; and Does 14 through 100, inclusive, Superior Court of the State of California In
and For the County of Alameda; deposition testimony, February 2019. Case No.
RG16807477
Marisa Rangel And Jerrid Jeter, Sr., individually and as Parents and Next Friends of Jerrid
Jeter-Gilmon, Jr., a Minor v. Jenifer Kowalik, M.D., Jenifer Kowalik, MD PA, Jenifer Kowalik,
MD PA D/B/A Centex Family and ObGyn Associates, and Central Texas Medical Center
Inc, District Court of Hays County, Texas, 428th Judicial District; deposition testimony,
January 2019. Cause No. 15-1154
Tracy Chen and Matthew Lucadano, as Aggrieved Employees v. Morgan Stanley Smith
Barney, LLC, and Does 1 through 20, inclusive; Superior Court of California County of
Orange; deposition testimony, January 2019. Case No. 30-2014-00724866-CU-OE-CXC.
Kimberly Hudson, and Thomas Earl Jackson, Jr., as Temporary Guardians of Kendric
Jackson, an Incapacitated Person v. Canadian National Railway Company; Mississippi
Export Railroad; Illinois Central Railroad Company; Illinois Central Corporation; Grand
Trunk Corporation, David W. Myers; and Diamante Jamarcus Lockhard; United States
District Court for the Southern District of Alabama Southern Division; deposition testimony,
October 2018. Action No. CV-2017-091162.00.
Donald Clynes v. City of Brownsville; District Court 107th Judicial District Cameron County,
Texas; deposition testimony, August 2018. Cause No. 2017-DCL-07638.
Michael Chatterton v. Beelman Ready Mix, Inc.; Circuit Court of the Twentieth Judicial
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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 23 of 51

Circuit St. Clair County, Illinois; trial testimony, August 2018. Cause No. 14-L-221.
Latoya Brown; Lawrence Blackmon; Herbert Anthony Green; Khadafy Manning; Quinnetta
Manning; Marvin Mcfield; Nicholas Singleton; Steven Smith; Bessie Thomas; and Betty
Jean Williams Tucker, individually and on behalf of a class of all others similarly situated v.
Madison County, Mississippi; Sheriff Randall S. Tucker, in his Official capacity; and
Madison County Sheriff’s Deputies John Does #1 through #6, in their Individual capacities;
United States District Court Southern District of Mississippi Northern Division; deposition
testimony, June 2018. Civil Action No. 3:17-cv-347WHB-LRA.
Michael Chatterton v. Beelman Ready Mix, Inc.; Circuit Court of the Twentieth Judicial
Circuit St. Clair County, Illinois; deposition testimony, June 2018. Cause No. 14-L-221.
U.S. Equal Employment Opportunity Commission v. JC Wings Enterprises, LLC, JC Wings,
LTD, JG Investments Enterprises, LLC, JG Investments, LTD, CK1 Enterprises, LLC, and
Ten Lbs, LTD d/b/a Bayou City Wings, In the United States District Court Southern District
of Texas Houston Division, deposition testimony, June 2018. Civil Act No. 4:16-CV-03245.
William M. Parrish and Margaret Parrish v. Ean Holdings, LLC and Andrea Valverde, In the
District Court Travis County, Texas 200th Judicial District, trial testimony, June 2018. Cause
No: D-1-GN-17-000413.
William M. Parrish and Margaret Parrish v. Ean Holdings, LLC and Andrea Valverde, In the
District Court Travis County, Texas 200th Judicial District, deposition testimony, May 2018.
Cause No: D-1-GN-17-000413.
Cora Greene v. Kempner Water Supply Corporation, In the District Court 27th Judicial
District Lampasas County, Texas, deposition testimony, May 2018. Cause No. 20315.
Zulema Perez San Miguel, Individually; as Independent Administrator of the Estate of Kevin
Daniel San Miguel Lopez; and as Next Friend of Julissa San Miguel; Kevin San Miguel, Jr;
and Noah San Miguel v. Clean Scapes Management Company, LLC; Goodwill Temporary
Services, Inc., d/b/a Goodwill Staffing Group, Inc., Bae Systems information and Electronic
Systems Integration, Inc., and Scag Power Equipment, Inc., In the District Court of Travis
County Texas 53rd Judicial District, deposition testimony, April 2018. Cause No.
D-1-GN-16-005140.
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Estate of Jordan Baker, by and through administrator, Janet Baker v. Juventino Castro, The
City of Houston, RPI Management Company, LLC, and RPI Interests I, LTD, In the United
States District Court Southern District of Texas Houston Division, deposition testimony
February 2018. Cause No. 4:15-cv-3405.
Balapuwaduge Mendis, on his own behalf and on behalf of all others similarly situated v.
Schneider National Carriers, Inc., a Nevada Corporation, United States District Court
Western District of Washington, deposition testimony February 2018. Cause No.
2:15-cv-00144-JCC.
Richard Patton v. Houston Independent School District, In the District Court of Harris
County, Texas 295th Judicial District, deposition testimony January 2018. Cause No.
2016-51917.
Mandy Thompson and Kevin Torrez, individually and as next friends and representatives of
Ayden Torrez, a minor v. St. David’s Healthcare Partnership, L.P., LLP, d/b/a St. David’s
Medical Center; Jeff E. Hagen, M.D.; Jeff E. Hagen, M.D., P.A., d/b/a Austin OBGYN; and
Maria E. Gutierrez, RNC, NP, MSN, In the District Court Travis County, Texas 353rd
Judicial District, deposition testimony January 2018. Cause No. D-1-GN-14-005096.
Jose Luis Alcantar, on behalf of himself and all others similarly situated v. Hobart Service,
Hobart Food Equipment Group, Itw Food Equipment Group, LLC, and Does 1 through 100,
inclusive, United States District Court, Central District of California, deposition testimony
December 2017. Cause No. 5:11-CV-1600-PSG (SPx).
Karen Cunningham, Individually, as Heir at Law, and as Representative of the Estate of
Steven Cunningham, Deceased; Sami Staley; Beatrice Cunningham; Jonathan Vigil;
Andrew Tkaczyk; Zachary Johnson; James Riley; Timothy Irons; Charles Billings; Nathan
Wilden; Christopher Davis; and Armando Cardona; and Daniel Luppino v. Nikki Hoke, as
Representative of the Estate of Gregory M. Hoke, Deceased; Bordur Studios Coach
Leasing LLC; and Big Sexy Grey Bus LLC; and Nikki Hoke, Individually, as Representative
of the Estate of Gregory M. Hoke, Deceased, and as Next Friend of E.H. and H.H., minor
children of Gregory M. Hoke, Deborah Hoke, Individually, and Russel Hoke, Individually v.
Bridgestone Americas Tire Operations, LLC, a foreign Company which is the successor to
Bridgestone/Firestone North American Tire, LLC, In the District Court of Hudspeth County,
Texas 394th Judicial District, deposition testimony November 2017. Cause No.
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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 25 of 51

CV-04569-394.
Jose F. Andino, individually and on behalf of himself and others similarly situated v. Kaiser
Foundation Hospitals, a California Corporation, and Does 1 through 100, inclusive,
Superior Court of the State of California For the County of Alameda, deposition testimony
October 2017. Case No. RG11580548.
Jeffrey Fadness v. Charter Communications, Inc., In the District Court Travis County, Texas
261st Judicial District, deposition testimony October 2017. Cause No. D-1-GN-17-000119.

Paris Shoots, Jonathan Bell, Maxwell Turner, Tammy hope, Phillipp Ostrovsky, Brenda
Brandt, Anissa Sanders, Najai McCutcheon, and Leticia Rodriquez, on behalf of
themselves, the Proposed Rule 23 Classes and others similarly situated, v. IQOR Holdings,
Inc., United States District Court District of Minnesota, deposition testimony August 2017.
Case No. 0:15-cv-00563-SRN-SER.
Timothy K. Sargis and Dawn M. Sargis, Individually and as Next Friends of Madisyn Marie
Loher, A Minor and as Personal representatives of the Estate of Michelle Loher, and Gary
S. Loher, II v. HS Centex Trucking, LLC, Kevin Clay and USAA General Indemnity
Company, In the District Court Coryell County, Texas 52nd Judicial District March 2017.
Cause No. DC-16-44861.

Stacey Burkhart and Brandon Burkhart Individually and As Parents and Next Friends of
Austin Burkhart, a Minor v. United Regional Health Care System, Inc. d/b/a United Regional
Hospital, United Regional Hospital, Texoma Women’s Clinic, P.A. d/b/a The Women’s
Center, and Lawrence Y.H. Young, M.D., In the District Court 78th Judicial District Wichita
County, Texas November 2016. Cause No. 178046B.
Troy Slack, Jacob Grismer, Richard Erickson, Scott Praye, Gary H. Roberts, Robert P.
Ullrich, Henry Ledesma, Timothy Helmick, Dennis Stuber, Eric Dublinkski, Sean P. Forney
v. Swift Transportation Co., of Arizona, LLC., United States District Court Western District of
Washington at Tacoma, deposition testimony November 2016. Case No.
3:11-cv-05843-BHS.

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 26 of 51

Richard Trusz v. UBS Realty Investors LLC and UBS AG, United States District Court
District of Connecticut, deposition testimony September 2016. Civil Action No. 3:09-CV-268
(DJS).
Amy L. Schneider and Janet E. Breneman, individually and on behalf of others similarly
situated, v. Union Hospital, Inc., United States District Court Southern District of Indiana
Terre Haute Division, deposition testimony June 2016. Case No. 2:15-cv-204-JMS-DKL.
Corey Khansari, Debra Khansari and Michael Khansari v. The City of Houston, Chief of
Police Charles A. McClelland, Jr., Officer William E. Rutherford, Officer Candace M.
Bradshaw Vaughn, Officer Jillian McGowan, Officer Maria Hernandez, Officer Sean Hunter,
Officer Jorge Luis Herrera, and Officer Walter Gaw, United States District Court Southern
District of Texas Houston Division, trial testimony April 2016. Civil Action No.
4:13-CV-02722.
Donald and Mary Trichel, individually and as Next Friends of Nicholas Trichel v. Union
Pacific Railroad Company and Jeremy Ray Hampton, In the District Court of Harris County,
Texas 125th Judicial District, deposition testimony April 2016. Cause No. 2014-23177.
Virginia Nester and Robert Scott Nester, Individually and As Next Friends of C.N. and S.N.,
Minors v. Textron, Inc. d/b/a E-Z-GO United Rentals, Inc. f/k/a RSC Holdings, Inc. and/or
RSC Equipment Rental, In the United States District Court for the Western District of Texas
Austin Division, trial testimony March 2016. Case No. 1:13-CV-000920-LY.
Chris Elliott O/B/O Himself and O/B/O All Other Similarly Situated, v. Schlumberger
Technology Corporation and Schlumberger Limited (Schlumberger N.V.), United States
District Court for the District of North Dakota Southeastern Division, deposition testimony
March 2016. Civil Action No. 3:13-cv-00079.
United States of America, ex rel. Louis Scutellaro v. Capitol Supply, Inc., United States
District Court District of Columbia, deposition testimony February 2016. Civil Action No.
10-cv-1094 (BAH).
Monica Hague v. University of Texas Health Science Center at San Antonio, In the United
States District Court for the Western District of Texas San Antonio Division, trial testimony
January 2016. Civil Action No. SA-11-CA-1101-OG.
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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 27 of 51

Arleen Delaronde v. Legend Classic Homes, Ltd., Bella Vista C.M.I., Ltd., In the United
States District Court for the Southern District of Texas Houston Division, trial testimony
December 2015. Civil Action No. 4:14-cv-1578.
Genoveva Guzman and Abel Ochoa, Individually and as Parents and Next Friend of Maria
Guadalupe Ochoa v. Tenet Healthcare Corporation, Hughan Frederick, M.D., Isis Obstetrics
& Gynecology, LLC, A. Ellery, RN, North Fulton Hospitalist Group, LLC D/B/A North Fulton
Regional Hospital A/K/A Tenet North Fulton Hospital, and John Does 1-10, In the State
Court of Fulton County, State of Georgia, deposition testimony September 2015. Civil
Action No. 13EV018499E.
Jose Arellano and Juan Montoya, individually, and on behalf of all others similarly situated
v. Container Connection of Southern California, Inc., a California Corporation; and Does 1
through 100, Superior Court of the State of California for the County of Los Angeles,
deposition testimony September 2015. Case No. BC500675.
Monica Hague v. University of Texas Health Science Center at San Antonio, In the United
States District Court for the Western District of Texas San Antonio Division, deposition
testimony August 2015. Civil Action No. SA-11-CA-1101-OG.
Jesus Holguin, Individually and o/b/o The Estate of Maria E. Holguin, Deceased, Estevan
A. Gonzales, Jesus Ramon Holguin and Kassandra M. Holguin, Minor Children v. Baptist
St. Anthony Health System, In the District Court of Potter County, Texas, deposition
testimony July 2015. Case No. 101,910-D.
Fred Devries, Ruby Teich, Janine Natoli, Rafael Santiago, Mark Malter, Adam Schwartz,
individually and on behalf all others similarly situated v. Morgan Stanley & Co. LLC, f/k/a
Morgan Stanley & Co. Incorporated, Morgan Stanley Smith Barney LLC, and Morgan
Stanley, In the United States District Court for the Southern District of Florida, deposition
testimony July 2015. Case No. 9:12-cv-81223-KAM

Mark Virant v. Encana Oil & Gas (USA), Inc. and Eric Marsh, Individually, In the District
Court of Tarrant County, Texas 153 Judicial District, deposition testimony July 2015. Case
No. 153-266960-13.

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 28 of 51

Virginia Nester and Robert Scott Nester, Individually and As Next Friends of C.N. and S.N.,
Minors v. Textron, Inc. d/b/a E-Z-Go, United Rentals, Inc. f/k/a RSC Holdings, Inc. and/or
RSC Holdings, Inc. and/or RSC Equipment Rental, In the United States District Court for
the western District of Texas Austin Division, deposition testimony June 2015. Case No.
1:13-CV-000920-LY.
Lisa Rindfleisch, Tiffany Melendez, Michelle Gentile, Laurie Baker and Christina Nelmes, on
behalf of themselves and other similarly situated, v. Gentiva Health Services, Inc., In the
United States District Court for the Eastern District of New York, deposition testimony June
2015. Civil Action No. 1:10-CV-3288-SCJ.
Karen Oubre, Individually and o/b/o The Estate of Larry Oubre, Deceased v. Kyle Mezger,
M.D.; Christopher Thu, M.D.; and Capitol Anesthesiology Association, In the District Court
of Travis County, Texas 126th Judicial District, Texas deposition testimony May 2015.
Cause No. D-1-GN-14-000383.
Weird Times, LLC v. Sharon Ma and Doug Ma, In the District Court 353rd Judicial District
Travis County, Texas, trial testimony March 2015. Cause No. D-1-GN-12-001076.
Armida Rodriguez and Chea Hill, individually, and on behalf of all other similarly situated
and on behalf of the general public, v. Burlington Coat Factory Warehouse Corporation, a
New Jersey Corporation; Burlington Coat Factory of California LLC, a California Limited
Liability Company; and Does 1 through 50, inclusive, United States District Court - Central
District of California, deposition testimony February 2015. Case No.
2:13-cv-02426-DDP-RZ.
Guang Tian, Yan Nie, Jing Jian Wu, Zhen Sheng Yin, Tie Quan Ma, as individuals, and
Ming Fang Tie, Yu Hong Chang, Yi Wu, Bao Jie Zhang, Chao Hui Liu, on Behalf of
Themselves and all others similarly situated, and Christopher Cavaliere and Steven Lee, on
behalf of themselves and as PAGA representatives v. Ma Laboratories, Inc., Abraham C.
Ma, also known as Chih Keng Ma, and Christine Rao, also known as Ruiting C. Rao,
Superior Court of the State of California County of Santa Clara Unlimited Jurisdiction,
deposition testimony January 2015. Case No. 1-11-CV-195373.
Uzoamaka Enezuagu; Yoseph Awlachew; Kiflom Birhane; Desalgne Zema; Simon
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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 29 of 51

Gebrekiros; Jacqueline Jackson; Abebech Kassie; Abdou Ouedraogo; Raquel Pryce-King;
Ephrem Tessema; Yonas Woldemicael; Shamara Wright; Helen Zegeye; Alemayehu
Zeleke; Jekeia Sledge; Ann-Marie Glanville; Alex Garrett; Sara Kebeta; Getnet Retta;
Emmanuel Vincent; Tatek Zema v. Board of Trustees of the University and Does 1 through
10 inclusive, Superior Court of the District of Columbia Civil Division, deposition testimony
November 2014. Case No. 2013-CA-2219-B.
Sergio Gutierrez, an individual; Hector Salazar, an individual, both individually on behalf of
themselves and on behalf of all other similarly situated current and former employees of
Defendant Commerce Casino v. California Commerce Club, Inc. doing business as
Commerce Casino, and Does 1 through 50, inclusive, Superior Court of the State of
California for the County of Los Angeles, deposition testimony November 2014. Case No.
BC360704.
Yvette Anderson, et al., v. County of Ventura; and Does 1-10, inclusive, United States
District Court, Central District of California, deposition testimony July 2014. Case No.
CV13-03517-STO (VBKx).

Jesus Castro Romo v. The United States of America, United States District Court, District of
Arizona, trial testimony July 2014. Case No. CV12-0041-RCC.
Ngan Huynh and Tuan M. Nguyen Individually and As Parents, Legal Guardians and Next
Friends of Jonathan Nguyen, A Minor v. St. David’s Healthcare Partnership, L.P.; LLP
Individually and d/b/a St. David’s North Austin Medical Center a/k/a North Austin Medical
Center; Round Rock Hospital, Inc.,; St. David’s Foundation p/k/a St. David’s Health Care
System, Inc.,; Renaissance Women’s Group, P.A.; Tara A. Mills, M.D.; Devin M. Garza,
M.D.; Kristen Barkow a/k/a Kristen Calnan, NP, In the District Court Travis County, Texas,
200th Judicial District, deposition testimony July 2014. Cause No. D-1-GN-11-002142.
Veronica Ochoa Valenzuela and Cesar De Viana, husband and wife v. Ford Motor
Company, a Foreign Corporation, In the United States District Court for the District of
Arizona, trial testimony May 2014. Case No. 15-16388.
Johnson, et al v. York Claims Service, Inc., Superior Court of the State of California in and
for the County of Sacramento, trial testimony May 2014. Case No.

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 30 of 51

34-2008-00008447-CU-OE-GDS.
Michael Mercieca v. Tracey Rummel, and Microsoft Corporation, In the District Court 353rd
Judicial District Travis County, Texas, trial testimony May 2014. Cause No.
D-1-GN-11-001030.
Johnson, et al v. York Claims Service, Inc., Superior Court of the State of California in and
for the County of Sacramento, deposition testimony April 2014. Case No.
34-2008-00008447-CU-OE-GDS.

Yadira Hernandez v. R.E.S.A., Inc., d/b/a Keller Williams Realty and Carolina Salcedo
Cuevas, In the District Court 131st Judicial District, Bexar County, Texas, trial testimony
April 2014. Cause No. 2011-CI-05812.
Charles E. Amos, II v. Plan Administrator of Orion Healthcorp, Inc., Employee Benefit
Plans, Orion Healthcorp, Inc., Employee Benefit Plans, Orion Healthcorp, Inc., RMI
Physician Services Corporation, Chi T. “Cindy” Luu, Kimberly Singleton, RMI Physician
Services Corporation Employee Benefit Plans, Plan Administrator of RMI Physician
Services Corporation Employee Benefit Plans, In the United States District Court for the
Southern District of Texas Houston Division, deposition testimony April 2014. Case No.
4:11-CV-04623.
Gerald Bramlett, v. Dimensional Investment LLC before the American Arbitration
Association, Austin, Texas, arbitration testimony February 2014. Case No. 70-160-202-13.
Gerald Bramlett, v. Dimensional Investment LLC before the American Arbitration
Association, Austin, Texas, deposition testimony December 2013. Case No. 70-160-202-13.

Renee M. Hawkins, Individually and on behalf of others similarly situation v. Alorica,
Incorporated, United States District Court for the Southern District of Indiana Terre Haute
Division, deposition testimony December 2013. Case No. 2:11-cv-0283 JMS-WGH.
Jodi Soukup, Individually, and as Parent, Legal Guardian and Next Friend of Ryan Burford,
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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 31 of 51

A Minor v. Methodist Healthcare Ministries of South Texas, Inc. d/b/a Southwest Texas
Methodist Hospital, and/or d/b/a or a/k/a/ Methodist Hospital; Columbia/HCA Healthcare
Corporation of Central Texas; Methodist Healthcare Ministries of South Texas Inc.; Patricia
K. Brougher, M.D. and Patricia K. Brougher, M.D., P.A., In the District Court 45th Judicial
District Bexar County, Texas, deposition testimony December 2013. Cause No.
2010CI17368.
Ben Deason v. Jennifer Newsom, in the 145th District Court in and for the County of
Nacogdoches County, Texas, deposition testimony October 2013
Tracy Windrum, Individually, as representative of the Estate of Lancer Windrum, and on
behalf of her minor children Bethany Windrum, Jacob Windrum, and Holly Windrum v.
Victor Kareh, M.D., Harpaul Gill, M.D., North Cypress Medical Center, North Cypress
Medical Center Operating Company, GP, LLC, North Cypress Medical Center Operating
Company, LTD and Coresource, Inc., In the District Court of Harris County, Texas, 133rd
Judicial District, trial testimony October 2013
Victoria “Anna” Janssen v. O’Reilly Automotive Stores, Inc., In the United States District
Court for the Northern District of Texas Wichita Falls Division, Wichita Falls, Texas, trial
testimony September 2013
Denise K. Aguilar v. St. David’s Healthcare Partnership, LP, LLC d/b/a South Austin Medical
Center, American Arbitration Association, Austin, Texas, deposition testimony August 2013
Deann Hojnacki v. Trisun Healthcare, LLC, Arbitration Austin, Texas, deposition testimony
August 2013

Yadira Hernandez v. R.E.S.A., Inc., D/B/A Keller Williams Realty and Carolina Salcedo
Cuevas, In the District Court 131st Judicial District, Bexar County, Texas, deposition
testimony May 2013
Y. Hoang Do, M.D. v. Texas Health and Human Services Commission, Office of Inspector
General, Before the Health and Human Services Commission Appeals Division, Travis
County, Texas, trial testimony May 2013

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 32 of 51

David Meyer, Individually and o/b/o The Estate of Doreen Rae Meyer, Deceased, Sunny
Ruud, Brandy Cebula, and Jon Novitsky o/b/o Krystin Novitsky, Minor Child v. Stephen
Bodi, P.A. and M.D.’s Cyber Clinic, P.A. D/B/A Northwest Diagnostic Clinic, In the District
Court of Williamson County, Texas 368th Judicial District, deposition testimony March 2013
Instant Technology, LLC, an Illinois Limited Liability Company, v. Elizabeth Defazio, Laura
Rehn, Megan Marker, Bethany Meek, Erin Bauer, Joel Katz, Andrea Katz, individuals and
Connect Search, LLC, a Delaware Limited Liability Company, In the United States District
Court for the Northern District of Illinois, Eastern Division, deposition testimony January
2013
United Biologics, LLC, D/B/A United Allergy Labs & Nicolas Hollis v. Texas Allergy, Asthma
and Immunology Society; Stuart L. Abramson, MD, PHD; Wesley W. Stafford, MD;
Theodore M. Freeman, MD; William R. McKenna, MD and Michael P. Vaughn, MD, PHD, In
the District Court of Travis County, Texas 353rd Judicial District, deposition testimony
January 2013
Lisa Rindfleisch, Tiffany Melendez, Michelle Gentile, Laurie Baker and Christina Nelmes, on
behalf of themselves and others similarly situated, v. Gentiva Health Services, Inc., In the
United States District Court Northern District of Georgia Atlanta Division, deposition
testimony January 2013
Jose Luis Alcantar, on behalf of himself and all others similarly situated v. Hobart Service,
et al., United States District Court for the Western District of Texas, deposition testimony
January 2013
Certain Underwriters at Lloyd’s London and Professional Liability Insurance Services, Inc.
v. IMA of Kansas, Inc., In the District Court of Travis County, Texas 353rd Judicial District,
trial testimony
Equal Employment Opportunity Commission v. Valero Refining – Texas LP, In the United
State District Court for the Southern District of Texas Galveston Division, deposition
testimony October 2012

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 33 of 51

United Biologics, LLC, Formerly d/b/a United Allergy Services, Formerly d/b/a United
Allergy Labs & Nicolas Hollis v. Texas Allergy, Asthma and Immunology Society; Stuart L.
Abramson, MD, PHD; Wesley W. Stafford, MD; Theodore M. Freeman, MD; William R.
McKenna, MD, and Michael P. Vaughn, MD, PHD., In the District Court of Travis County,
Texas 353rd Judicial District, deposition testimony October 2012
Y. Hoang Do, M.D. v. Texas Health and Human Services Commission, Office of Inspector
General, before the Health and Human Services Commission Appeals Division, Texas,
deposition testimony October 2012
Xochitl Segovia, v. Williams Brothers Construction Company, Inc., In the District Court of
Harris County, Texas 333 Judicial District, trial testimony August 2012
ADP, Inc., a Delaware Corporation v. National Merchant Alliance, LLC, a Nevada Limited
Liability Company, United States District Court for the Western District of Texas, deposition
testimony June 2012
Dustin R. Thompson, v. J4 Development, LP, In the District Court of Travis County, Texas
200th Judicial District, deposition testimony June 2012

Certain Underwriters at Lloyd’s London and Professional Liability Insurance Services, Inc.
v. IMA of Kansas, Inc., In the District Court of Travis County, Texas 353rd Judicial District,
deposition testimony May 2012
James R. Irion, III and Veniece M. Irion v. Sunrise Senior Living Management, Inc., D/B/A
Brighton Gardens of Austin; and Prime Care Seven, LLC D/B/A Brighton Gardens of Austin,
United States District Court Western District of Texas Austin Division, deposition testimony
May 2012
Elsa Ortega on behalf of S.L.O. and J.L.O. minors, et al v. United States of America, Jose
Vicente Gaytan-Alcaya, et al, v. United States of America; Elsa Ortega and John Doe
Ortega, Husband and Wife, In the United States District Court for the District of Arizona,
deposition testimony April 2012

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Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 34 of 51

William Kierre v. Gerry Lawler, M.D. and Hendrick Anesthesia Network, In the District Court
of Taylor County 104th Judicial District, trial testimony April 2012
Dawn Leamon, v. KBR, Inc.; et al, In the United States District Court for the Southern
District of Texas Houston Division deposition, testimony April 2012

Wilson Industries, L.P., v. Select Energy Services, LLC; and Bell Supply, LLC; In the District
Court of Ector County, Texas 244th Judicial District, deposition testimony March 2012
Debra Nicholas v. San Antonio Water System, In the District Court 57th Judicial District
Bexar County, Texas, trial testimony March 2012
Lielonnie R. Lewis v. Save Mart Supermarkets and Does One through Fifty, inclusive,
Superior Court of the State of California in and for the County of Alameda, deposition
testimony February 2012

Flordeliza Escano, Marila P. Maximo, Joel T. Catublas, and Penny Burney, on behalf of
themselves and behalf of all other similarly situated, v. Kindred Healthcare Operating, Inc.,
a Delaware Corporation, Kindred Healthcare, Inc., a Delaware Corporation, Specialty
Hospitals of Southern California, a business form unknown, and Does 1 through 100,
United States District Court Central District of California (Western Division – Los Angeles),
deposition testimony February 2012
Anthony Stout, on behalf of himself and others similarly situated, v. Universal Ensco, Inc.,
United States District Court Southern District of Texas Houston Division, deposition
testimony November 2011
Lashone Purnell, as an individual and on behalf of all employees similarly situated, v.
Sunrise Senior Living Management, Inc., and Does 1 through 50, inclusive, United States
District Court Central District of California Southern Division, deposition testimony August
2011

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Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 35 of 51

Jamie Leigh Jones v. Halliburton Company d/b/a KBR Kellogg Brown & Root (KBR);
Kellogg Brown & Root Services, Inc.; Kellogg Brown & Root International Inc.; Kellogg
Brown & Root, LLC; Kellogg Brown & Root, Inc.; Kellogg Brown & Root Inc.; Kellogg Brown
& Root, S. de R.L.; Kellogg Brown & Root (KBR), Inc.; KBR Technical Services, Inc.;
Overseas Administrative Services, Ltd.; Eric Iler, Charles Boartz; Several John Doe Rapists
and the United States of America, In the United States District Court for the Southern
District of Texas (Houston Division), trial testimony June 2011
Debbie Goodwill, Individually and on Behalf of the Estate of Larry Goodwill, Cody Goodwill,
and Wendy Christian v. United Parcel Service, Inc., et al, In the U.S. District Court for The
Western District of Texas Austin Division, trial testimony June 2011
Veronica Ochoa Valenzuela and Cesar De Viana, husband and wife v. Ford Motor
Company, a Foreign Corporation, In the United States District Court for the District of
Arizona, deposition testimony
Jamie Leigh Jones v. Halliburton Company d/b/a KBR Kellogg Brown & Root (KBR);
Kellogg Brown & Root Services, Inc.; Kellogg Brown & Root International Inc.; Kellogg
Brown & Root, LLC; Kellogg Brown & Root, Inc.; Kellogg Brown & Root Inc.; Kellogg Brown
& Root, S. de R.L.; Kellogg Brown & Root (KBR), Inc.; KBR Technical Services, Inc.;
Overseas Administrative Services, Ltd.; Eric Iler, Charles Boartz; Several John Doe Rapists
and the United States of America, In the United States District Court for the Southern
District of Texas (Houston Division), deposition testimony May 2011
Michael L. Collier, Ph.D. v. Texas Tech University and John Whitmore in his Official
Capacity, In the District Court 99th Judicial District Lubbock County, Texas, trial testimony
May 2011

Debbie Goodwill, Individually and on Behalf of the Estate of Larry Goodwill, Cody Goodwill,
and Wendy Christian Plaintiffs, Cecelia Center, Individually and as Administrator of the
Estate of George Reagan Center Intervenors, v. United Parcel Service, Inc., Tire Centers,
LLC d/b/a TCI, and The Goodyear Tire & Rubber Company, In the United States District
Court for the Western District of Texas Austin Division, deposition testimony March 2011
Albert Kevin Martin, A/K/A Kevin Martin v. City of San Antonio and Its Agent, San Antonio

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 36 of 51

Water System, In the District Court 224th Judicial District, Bexar County, Texas, trial
testimony February 2011
Delanie Ney, v. iProfile, LLC, Accord Human Resources, Inc. Virgo Capital Fund I, LP,
Hemanth Parasuram, Guhan Swaminathan and Arun Prakash, Arbitration Cause No.
701600042810, Austin, Texas, arbitration testimony January 2011
State of Texas ex rel., Ven-A-Care of the Florida Keys, Inc. v. Alpharma USPD f/k/a
Barrenational, Inc., Purepac Pharmaceutical Co., Actavis Mid Atlantic LLC, Actavis
Elizabeth LLC, Barr Pharmaceuticals, Inc., Barr Laboratories, Inc., Duramed
Pharmaceuticals, Inc., Pliva, Inc. f/k/a Sidmak Laboratories, Inc., Odyssey
Pharmaceuticals, Inc., PAR Pharmaceutical, Inc., PAR Pharmaceutical Companies, Inc.,
Watson Pharmaceuticals, Inc., Watson Pharma, Inc. f/k/a Schein Pharmaceutical, Inc.,
Rugby Laboratories, Inc., Oclassen Pharmaceuticals, Inc., Marsam Pharmaceuticals, Inc.,
and Andrx Pharmaceuticals, Inc., In the District Court of Travis County, Texas, 419th
Judicial District, trial testimony, January 2011
Kevin Blackwell and Amber Blackwell, Individually and As Next Friend of K.B. and S.B.,
Minors v. Nissan Motor CO., LTD. And Nissan North America, Inc., In the United States
District Court for the Eastern District of Texas Beaumont Division, deposition testimony
January 2011
Nicholas Tableriou, Individually, and as Administrator of the Estate of Jane Tableriou,
Deceased, Nicole Tableriou, and Brett Tableriou v. John Marsden, M.D., Marsden One GP,
LLC, Marsden One, LTD., Marsden Management, LLC, and The American Institute of
Gastric Banding, LTD., D/B/A True Results, In the District Court Travis County, Texas 261st
Judicial District, deposition testimony October 2010
Prudence Adams v. Centex Freight Lines, LLC, In the District Court Travis County, Texas
Judicial District, trial testimony October 2010

Jeanette Eberhart; Hamilton Beaux O’Keady-Elicock; Howard Hill; and Philip Marc Orlow v.
Frye Claims Consultation and Administration, Inc. a California Corporation, In the Superior
Court of the State of California, Alameda County, deposition testimony September 2010

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 37 of 51

Shaunetta Eddings, individually and on behalf of a class of similarly situation individuals, v.
Health Net, Inc., In the United States District Court for the Central District of California,
deposition testimony September 2010
Equal Employment Opportunity Commission and Connie Beseda, v. Zachry Industrial, Inc.
(San Antonio) F/K/A Zachry Construction Corporation, (San Antonio), In the United States
District Court for the Western District of Texas San Antonio Division, deposition testimony
September 2010
Candice Warde Rodriguez, Individually and on Behalf of Benjamin Wallace Rodriguez, a
Minor, v. The United States of America, In the United States District Court, Eastern District
of New York, deposition testimony August 2010
Ronica R. Tabor on behalf of herself and all others similarly situated, Dacia S. Gray on
behalf of herself and all others similarly situated, v. Hilti, Inc. a Domestic For Profit Business
Corporation, and Hilti of America, Inc., a Foreign For Profit Business Corporation, In the
United States District Court for the Northern District of Oklahoma, deposition testimony
August 2010
State of Texas ex rel., Ven-A-Care of the Florida Keys, Inc. v. Alpharma USPD f/k/a
Barrenational, Inc., Purepac Pharmaceutical Co., Actavis Mid Atlantic LLC, Actavis
Elizabeth LLC, Barr Pharmaceuticals, Inc., Barr Laboratories, Inc., Duramed
Pharmaceuticals, Inc., Pliva, Inc. f/k/a Sidmak Laboratories, Inc., Odyssey
Pharmaceuticals, Inc., PAR Pharmaceutical, Inc., PAR Pharmaceutical Companies, Inc.,
Watson Pharmaceuticals, Inc., Watson Pharma, Inc. f/k/a Schein Pharmaceutical, Inc.,
Rugby Laboratories, Inc., Oclassen Pharmaceuticals, Inc., Marsam Pharmaceuticals, Inc.,
and Andrx Pharmaceuticals, Inc., In the District Court of Travis County, Texas, 419th
Judicial District, deposition testimony July 2010
Randall Barnett v. City of Austin, et al.; 353rd Judicial District Court, Travis County, Texas,
hearing testimony May 2010
Lugo, et al., v. Farmers Pride, In the United States District Court for the District of
Pennsylvania, deposition testimony May 2010
William Kierre v. Gary Lawler, M.D. and Hendrick Anesthesia Network, In the District Court,
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Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 38 of 51

Taylor County, Texas, 104th Judicial District, deposition testimony April 2010
Ann Otsuka, an individual and on behalf of all others similarly situated; Janis Keefe, an
individual; Corinne Phipps, and individual; Justin Kiser, an individual; and Renee Davis v.
Polo Ralph Lauren Corporation; Polo Retail, LLC; Polo Ralph Lauren Corporation, doing
Business in California as Polo Retail Corporation; and Fashions Outlet of America, Inc.,
United States District Court Northern District of California, trial testimony March 2010
Wai Chan, On behalf of herself and all others similarly situated v. Wells Fargo Financial,
Inc., In the United States District Court for the Western District of Missouri, deposition
testimony February 2010
Billy Petty, Edward Petty and Amanda Stewart v. Devesh Ramnath, M.D., In the District
Court Administratively transferred to the 95th Judicial District Dallas County, Texas,
deposition testimony February 2010
Luna v. Weddington, In the District Court of Harris County, Texas Judicial District 234, trial
testimony January 2010

Ann Otsuka, an individual and on behalf of all others similarly situated; Janis Keefe, an
individual; Corinne Phipps, and individual; Justin Kiser, an individual; and Renee Davis v.
Polo Ralph Lauren Corporation; Polo Retail, LLC; Polo Ralph Lauren Corporation, doing
Business in California as Polo Retail Corporation; and Fashions Outlet of America, Inc.,
United States District Court Northern District of California, deposition testimony December
2009
Mark Scherer, Doug Paslay and Hazel Bailey, individually, and on behalf of all other
similarly situated v. Duke Energy Fossil-Hydro California Inc., a Delaware Corporation, and
Wood Group Power Operations, Inc. A Nevada Corporation and Does 1 to 50, in the
Superior Court of the State of California, County of Los Angeles, deposition testimony
December 2009
Michael K. McLennan, v. Applied Materials, Inc., United States District Court Western
District of Texas Austin Division, deposition testimony December 2009

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Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 39 of 51

Wilfredo Cruz, Matthew Allbee, Guadalupe Varela, Raul Torres, and Ken Joseph,
individually and on behalf of a class of similarly situation persons, v. Unilock Chicago, Inc.,
an Illinois Corporation, In the Circuit Court of the Sixteenth Judicial District Kane County,
Illinois, deposition testimony December 2009
Daniel Friedenbach, Individually and on behalf of all survivors of the Estate of Lorie Frazier
Friedenbach, v. Gary A. Croll, in the District Court of Dallas County, Texas, 14th Judicial
District, deposition testimony November 2009

Fermin Cortez, et al., v. Nebraska Beef, Inc., and Nebraska Beef, LTD., David Chuol, et al.,
v. Nebraska Beef, LTD., The United States District Court For The District of Nebraska,
deposition testimony November 2009
Jeff Gebenus and Wesley Chong, individuals, on behalf of themselves and others similarly
situated v. Rite Aid Corporation, a Delaware corporation, and Thrifty Payless, Inc., a
California Corporation, in the Superior Court Of Washington For King County, deposition
testimony November 2009
Margaret A. Guerra v. San Antonio Water System; Pending in the 73rd Judicial District
Court, Bexar County, Texas, deposition testimony September 2009
David and Esther Luna v. Lloyd Damon Weddington, M.D. and Diabetes Center of America,
In The District Court Of Harris County, Texas, 234Th Judicial District, deposition testimony
September 2009
Wilfredo Cruz, Matthew Albee, Guadalupe Varela And Raul Torres, Individually and on
behalf of a class of similarly situated persons, v. Unilock Chicago, Inc., An Illinois
Corporation, and Jonathon Harn, An Individual, In the Circuit Court Of Sixteenth Judicial
District, Kane County, Illinois, deposition testimony September 2009
Kent Schmidt, v. KMS Retail-Ben White, LPKMS Retail Euless, LA, Kent Stainback, d/b/a
The Stainback Organization, Pete Becerra, Jimmy Evans Company, Ltd., In The District
Court, 345th Judicial District, Travis County, Texas, deposition testimony August 2009

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Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 40 of 51

Howard Hopkins et al, v. The First American Corporation And First American Real Estate
Tax Service, In The United States District Court Of Texas, Fort Worth Division, deposition
testimony July 2009
Westin Casuarina Las Vegas, Hotel, Casino & Spa v. The Coaching Center, LLC, Before
The American Arbitration Association, Arbitration meeting June 2009
Billy Ray Tratree v. B.P. Pipelines, Inc., Kelley Gleason and Roy Bowden, in the United
States District Court for the Southern District of Texas, deposition testimony June 2009
Kent Schmidt, v. KMS Retail-Ben White, LPKMS Retail Euless, LA, Kent Stainback, d/b/a
The Stainback Organization, Pete Becerra, Jimmy Evans Company, Ltd., In The District
Court, 345th Judicial District, Travis County, Texas, deposition testimony May 2009
Juan Manual Lopez-Verduzco, v. CTNA, et al Arizona Superior Court, County Of Maricopa,
deposition testimony April 2009
James J. Byerlotzer v. Key Energy Services, Inc., In The District Court Of Harris County,
Texas 55Th Judicial District, deposition testimony March 2009
David Liszt and Karen Liszt v. Richard B. Stovall, MD.; Luis Mignucci, MD., Individually and
d/b/a Luis Mignucci, MD., P.A., and d/b/a NeuroSpine Surgical Consultants; and Medical
Center of Plano; In the 219th District Court of Collin County, Texas, deposition testimony
March 2009
Marie Popek, Individually and on Behalf of Those Similarly Situated, v. Allied Barton
Security Services LLC, a Delaware Limited Liability Company; Allied Barton Security
Services LP, a Delaware Limited Partnership; and Does 1 through 30, inclusive, Superior
Court of the State of California for the County of San Francisco, CA., deposition testimony
December 2008
Charles Heath Leiber v. IE Miller Service L.P., IE Miller-Fowler L.L.C., and Noah Charles
Lawson, In the District Court 12th Judicial District of Grimes County, Texas, deposition
testimony November 2008

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 41 of 51

Billy Ray Tratree v. B.P. Pipelines, Inc., Kelley Gleason and Roy Bowden, in the United
States District Court for the Southern District of Texas, deposition testimony November
2008
Doris H. Gray, a married woman, v. Motorola, Inc., a Delaware Corporation, In the Superior
Court in and for Maricopa County in the State of Arizona, deposition testimony November
2008
Fred Klecka v. Allstate Insurance Company and Kathleen Abed, In The District Court 37th
Judicial District, Bexar County, Texas, trial testimony November 2008
Esteban Barron v. Larry Paul Hatter, Jr., And Estes Express Lines d/b/a Estes Express
Lines, Inc., In The District Court, 146Th Judicial District, Bell County, Texas, deposition
testimony October, 2008
UNIVAR USA, Inc., v. Stacey B. Blanton, In The District Court Harris County, Texas 61st
Judicial District, deposition testimony August 2008

Pedro Gonzalez v. City Of San Antonio, Acting By And Through Its Agent, City Public
Service Board d/b/a CPS Energy, In The District Court 225th Judicial District Bexar County,
trial testimony, San Antonio, Texas August 2008
Charles Young v. Brand Scaffold Services, LLC, In the Eastern District Court for the Eastern
District of Texas, Beaumont Division, deposition testimony June 2008.

Al Scott, Individually And As Administrator Of The Estate Of Dottie Scott, Deceased, And
Susan Scott And Sherri Scott v. Sandip V.Mathur, M.D. and Abilene Regional Medical
Center In The 42nd Judicial District Court of Taylor County Texas, deposition testimony
April 2008
International Association Of Firefighters, LOCAL 629 AFL-CIO, et al v. City Of Monroe, in
the United States District Court, Western District Of Louisiana, Monroe Division, deposition
testimony March 2008

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 42 of 51

Jennifer Jarmon and, Cassius Jarmon, Individually and as Co-Administrators of the estate
of Cassidy Jarmon, Deceased, and as Next Friends to Callie Jarmon, a minor child v.
Delbert J. Davison, Old American County Mutual, Prine Towing and Recovery, Inc.
COPART, Inc., and Daimler Chrysler Corporation, In the District Court, 412th Judicial
District, Johnson County, Texas, deposition testimony February 2008
Veronica Ramirez Aguilar, Individually, as representative of the estate of Mario Islas Minero,
and on behalf of all wrongful death beneficiaries v. Heart Employee Leasing, Inc. D/B/A and
Heart HR, and S and D Plumbing- Taylor LLC, In the District Court of Travis County, Texas,
353rd Judicial District, deposition testimony January 2008
Rolando Garcia v. Design Werks, Inc., In the District Court of Travis County, 98th Judicial
District, deposition testimony January 2008
Wilford Vogt, James P. Gauthier, and Humberto Reyna, Jr., for themselves and all others
similarly-situated United States District Court, for the Northern District Of Texas Dallas,
Dallas Division v. Texas Instruments Incorporated, deposition testimony November 2007
Randall Barnett, In The District Court, 353RD Judicial District v. City Of Austin, Powell
Austin Properties, Ltd., Powell Holdings, Inc., Makota, Inc., and Alejandro Herrera, Travis
County, Texas, deposition testimony November 2007
Cynthia S. Escamilla v. United Services Automobile Association, a Reciprocal, and Michael
Barry, arbitration November 2007

Cynthia S. Escamilla v. United Services Automobile Association, a Reciprocal, and Michael
Barry, deposition testimony October 2007

Jesus F. Diaz, Individually, as next friend of Marco A. Montoya and Racquel A. Diaz, minors
and as dependent Co-Administrator of the Estate of Maria E. Diaz; James L. Caldwell, as
dependent Co-Administrator of the Estate of Maria E. Diaz; Alejandro E. Diaz’ and Isidora
Gonzales v. General Motors Company, Autonation USA d/b/a Champion Chevrolet, H. E.
Butt Grocery Company and Gilbert E. Delgado III in the Probate Court, Travis County
Texas, deposition testimony August 2007

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 43 of 51

Angela Kay Warden, and husband, Brent Warden v. Wendell B. Ashby, MD, In The 108th
District Court, Potter County, Texas, trial testimony May 2007

Angela Kay Warden, and husband, Brent Warden v. Wendell B. Ashby, MD, In The 108th
District Court, Potter County, Texas, deposition testimony May 2007
William Montano and Doris Lucero v. Christmas By Krebs Corp., In The United States
District Court For The District Of New Mexico, deposition testimony March 2007

Daniel J. Davis, III and Yvonne Davis v. Worthy Warnack, M.D., Britt T. Daniel, M.D. and
Margaret Hollar, D.O.; In the District Court Dallas County, Texas 95th Judicial District,
deposition testimony February 2007
Julian James, Individually, Daphne Bates Harrison, et al. v. Harris County Sheriff’s
Department, et al, In the United States Court for the Southern District of Texas, Houston
Division, trial testimony January 2007
Sheila K. Robinson, Plaintiff, in the District Court of Brazos County, Texas v. Texas A&M
University, Defendant in the 85th Judicial District, College Station, Texas, trial testimony
January 2007
Viridiana Mata, Individually and Alejandro Rodriguez Individually, and all on Behalf of
Genoveva Rodriguez, a Minor v. Mission Hospital and Heather A. Daley, M.D. 370th
Judicial District in the District Court of Hidalgo County, Texas, deposition testimony
December 2006
Billy Ray Tratree v. B.P. Pipelines, Inc.; In the United States District Court for the Southern
District of Texas Houston Division, trial testimony October 2006
Julian James, Individually; Daphne Bates Harrison, Individually, et al. v. Harris County
Sheriff’s Department and William Wilkinson; In the United States District Court for the
Southern District of Texas Houston Division, deposition October 2006
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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 44 of 51

Texas Health and Human Services Commission, Medicaid and other Health and Human
Services Fraud and Abuse Program Integrity - Legal Action Relating to Dr. Turner Lewis,
M.D., administrative hearing September 2006
Billy Ray Tratree v. B.P. Pipelines, Inc.; In the United States District Court for the Southern
District of Texas Houston Division, trial testimony August 2006

Julian James, Individually, Daphne Bates Harrison, et al., v. Harris County Sheriff’s
Department, et al, In the United States Court for the Southern District of Texas, Houston
Division, testimony deposition March 2006
Michael Gibson v. Ondeo Nalco Energy Services, Inc. and Ondeo Nalco Company In the
United States District Court for the Southern District of Texas, Houston Division, trial
testimony February 2006
Frederick L. Risker v. Mahnaz Naveed Shah, M.D., Kelsey –Seybold Medical Group, P.A.,
and Gramercy Surgery Center, Ltd. D/B/A Gramercy Outpatient Surgery Center, deposition
testimony November 2005
Larry Butler and Cathy Butler, Individually and on Behalf of Brittany Butler, a minor, and Erin
Ferguson v. Kyle Kennedy, Russell Kennedy, Randi K. Kennedy, and Dana Harris,
deposition testimony September 2005
Cheryl Smith, Individually and as Guardian and Next Friend of Michelle Smith, an
Incapacitated Person v. Reyna Jean Noble, Ross Road Boring, Co., and Bobby L.
Lambright, and Mark Huber, Individually and on Behalf of Jessica Huber, A Minor v. Ross
Road Boring, Co., and Bobby L. Lambright, deposition and trial testimony August 2005
Amy Adkins v. Futurion Associates, Inc., deposition testimony August 2005

Jennifer Passi, Individually and a/n/f of Gracelyn Ann and Grant Michael Passi, Minor
Children and as Representative of the Estate of Michael Vincent Passi, deceased v. Dr.

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 45 of 51

Emery W. Dilling and Dr. Staton L. Awtrey; In Travis County, Texas, deposition testimony
August 2005
Tanya Valdez, as next friend of Alejandro Ruben Pando, a minor and Lelia Alvarez,
Individually and as representative of the estate of Ruben Pando, Jr., deceased v. Brinker
Texas, L.P. D/B/A On The Border Mexican Grill & Cantina, Brinker Chili’s Texas, Inc. D/B/A
On The Border Mexican Café, Brinker International, Inc, Chili’s Beverage Company, Inc.,
and Marlene Muniz as independent administrative and personal representative of the estate
of Felipe Ornelas, Jr., deposition testimony 2005
Vanessa Sinegaure, Individually and as a Representative of the Estate of Darnell Eugene
Sineguare v. Bally Total Fitness Corporation, et al; In the 334th Judicial District Court,
Harris County, Texas, deposition and trial testimony 2005
Jerry L. Bigelow, Individually and as Next Friend of B.B., J.N.B., J.T.B. and S.B., Minors v.
Living Picture AG, Living Picture Ltd., Living Picture GmbH and New York Lighter Co., Inc.;
U.S. District Court, Western District of Texas, Austin Division, deposition testimony 2005
Suresh Dutta v. David Pistenmaa, In the United States District Court for the Northern
District of Texas, Dallas Division, deposition and trial testimony 2005
Carrie Bennett, Individually as Representative of the Estate of Roy Edward Bennett,
Deceased, and as Next Friend of Lane Edward Bennett, Cody Lee Bennett and April Anne
Bennett v. Stephens Martin Paving, LP, Mobile Products, Inc. D/B/A Lay-Mor ; In the District
Court, Taylor County, Texas, 42nd Judicial District, deposition testimony 2005
Robert Edwin Wills v. Sysco Food Services of Austin, L.P. and Rickey Charles Green In the
82nd Judicial District Court of Robertson County, Texas, deposition testimony 2005
Michael Gibson v. Ondeo Nalco Energy Services, Inc. and Ondeo Nalco Company; In the
United States District Court for the Southern District of Texas, Houston Division, deposition
testimony 2005
Regina Kelly, et al. v. John Paschall et al.; In the United States District Court for the
Western District of Texas; Waco Division, deposition testimony 2004 and 2005

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Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 46 of 51

Charles White v. Technip USA Corporation and Technip, Inc.; In the 11th Judicial District
Court of Harris County, Texas, deposition testimony 2005
Mike Arismendez and Elva Arismendez v. Covenant Health Systems d/b/a Covenant
Medical Center; In the 237th District Court of Lubbock County, Texas, deposition testimony
2005
Linda Webb, Individually and on behalf of others similarly situated, v. Barnes Group Inc
States District Court, Northern District of Texas, Dallas Division; Consolidated Case No.
3-02CV2716-Rm class certification 2004
Margia Blankenship, et al. v. Marathon Oil, In the District Court of Harris County 281st
Judicial District, class certification 2004

Margia Blankenship, et al. v. Marathon Oil, In the District Court of Harris County 281st
Judicial District, deposition testimony 2004
Janet Herdman, et al. v. El Paso Energy Corporation et al., In the District Court of Harris
County, Texas 234 Judicial District, deposition testimony 2004
Sylvia Garcia and Rachel Garcia, Individually and on Behalf of the Estate of Richard
Garcia, Deceased v. Ted L. Phipps, M.D. and The Lubbock Digestive Disease Associates,
P.A. and Covenant Health Systems d/b/a Covenant Medical Center In The 237th District
Court of Lubbock County, Texas, deposition testimony 2004

Benavides v. Cushman et al, In the District Court of Harris County, Texas; 280th Judicial
District, trial testimony 2004

Jason Malone v. D.R. Horton – Emerald, Ltd.; In the 129th Judicial District Court of Harris
County, Texas, deposition testimony 2003

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Wage and Hour | Employment | Economic Damages

Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 47 of 51

Donald Castleberry and Mary Castleberry v. R. Douglas Mills, M.D., Nurse Jane Doe, St.
David’s Healthcare System, L.P. d/b/a North Austin Medical Center and Capital Emergency
Associates; In The 353rd Judicial District Court of Travis County, Texas, deposition
testimony 2003
Hammer Trucking, Inc. v. St. Paul Fire and Marine Insurance Company, et al.; In the 271st
Judicial District Court of Wise County, Texas, deposition testimony 2003
Rodney Wayne Hurt, M.D. v. Southwest Lincoln Mercury, deposition testimony 2003

Juan T. Gonzales v. S & B Engineers and Contractors, Ltd.; In the District Court of Harris
County, Texas; 280th Judicial District, deposition testimony 2003
John McKelvey and Lawanda McKelvey v. Arctic Pipe Inspection, Inc.; In the 333rd Judicial
District Court, Harris County, Texas, deposition testimony 2003
Gwendolyn Mason v. American Electric Power/Central Power and Light Company, In the
United States District Court, Western District, deposition testimony 2003
Linda Webb, Individually and on behalf of others similarly situated, v. Barnes Group Inc
States District Court, Northern District of Texas, Dallas Division; Consolidated Case No.
3-02CV2716-R deposition testimony 2003
Clawson v. Michael Landess and Covert Ford; In the district court of Travis County, Texas,
345th judicial district, deposition testimony 2003
Juan T. Gonzales v. S & B Engineers and Contractors, Ltd.; In the District Court of Harris
County, Texas; 280th Judicial District, trial testimony 2003
Benavides v. Cushman et al, In the District Court of Harris County, Texas; 280th Judicial
District, trial testimony 2003
Gwendolyn Mason v. American Electric Power/Central Power and Light Company, In the
United States District Court, Western District, trial testimony 2003
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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 48 of 51

Mandy De Leon v. Ivan Melendez, M.D et al., In the District Court, Hidalgo County, Texas,
332nd Judicial District, deposition testimony 2002
Nicole Terry, et al. v. Qwest Communications, Inc., Santos Ruiz Castillo, and Hertz
Equipment Rental, Inc.; In the 82nd District Court of Robertson County, Texas, deposition
testimony 2002
Maria Hilda Rodriguez v. Emerson Electric Co et al., In the United States District Court for
the Southern District of Texas, McAllen Division, deposition testimony 2002
In Re: Ambrocio Suarez, Jr., Deceased; In the Probate Court #2 of Harris County, Texas,
deposition testimony 2002
Robert L. Hunt and Lisa S. Hunt v. Century 21 Ripley Realty, Robert H. Carroll and Sylvia
K. Carroll; in the District Court Williamson County, Texas, 26th Judicial District, deposition
testimony 2002
Marcelyn K. Boone, Individually, and on behalf of similarly situated persons, Plaintiff v.
Union Carbide Corporation, Defendant; United States District Court, Southern District of
Texas, Galveston Division, deposition testimony 2002
Thomas J. Galland v. David L. Winn; In the District Court of Williamson County, Texas,
368th Judicial District, deposition testimony 2002
Tranquilino C. Munoz v. Newtron, Inc. and John Grant, In the District Court, Jefferson
County, Texas 60th Judicial District, deposition testimony 2002
Kirk Chi v. Dell Computer Corporation; In the United States District Court, Western District
of Texas, deposition testimony 2002
Pablo Reyes v. Glesby Marks Corporation; Atlas Air Conditioning Company, L.P.; Comfort
Systems U.S.A., Inc.; Atlas-Accurate Holdings, L.L.C. and John Bolan; In the District Court
of Harris County, Texas, 189th Judicial District, deposition testimony 2002

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 49 of 51

Gwendolyn Mason v. American Electric Power/Central Power and Light Company; In the
Southern District of Texas, Corpus Christi Division, deposition and trial testimony 2002
Dario Ibarra v. Pat Haas, d/b/a Patrick Haas Construction and Barton Creek Lakeside, LLC,
in the 345th Judicial District Court of Travis County, Texas, Personal Injury, deposition
testimony 2002
Benavides v. Cushman et al, In the District Court of Harris County, Texas; 280th Judicial
District, deposition testimony 2002
Alcatel USA, Inc. v. Cisco Systems, Inc., In the United States District Court for the Eastern
District of Texas, Sherman Division, deposition testimony 2002
Thomas J. Galland v. David L. Winn; In the District Court of Williamson County, Texas,
368th Judicial District, trial testimony 2002
Mandy De Leon v. Ivan Melendez, M.D et al., In the District Court, Hidalgo County, Texas,
332nd Judicial District, trial testimony 2002
Juanita Fletcher v. City of Houston, In the 189th Judicial District Court, Harris County,
Texas, trial testimony 2002
Keith Ferrell and Tracey Ware v Robert Robinson and the City of Houston, In the County
Civil Court at Law Number One, Harris County, Texas, deposition testimony 2001
Barbara LaRoche v. Daughters of Charity Health Services of Austin, et al, In the 126th
Judicial District Court of Travis County, Texas deposition testimony 2001

Brandenburg v. Georgetown Independent School District, United States District Court,
Western District of Texas, trial testimony 2001

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 50 of 51

EEOC v. BP Amoco et al., In the United States District Court for the Southern District of
Texas, Houston Division, deposition testimony 2000
Gomez v. United Parcel Service, United States District Court, Western District of Texas,
deposition testimony 2000
Pineda v. The City of Houston, In the United States District Court for the Southern District of
Texas, Houston Division, deposition testimony 2000
McDonald v. Dr. Sophia Burns, M.D., 268th District Court Fort Bend County, Texas,
deposition testimony 2000
Michelle Toussaint v. Sonic Restaurant, In the 136th District Court of Jefferson County,
Texas, deposition testimony 2000
Woolf v. Vincent, M.D., 9th District Court, Polk County Texas, deposition testimony 2000

Isaac Robinson as Next Friend of Chasity Amanda Robinson, Arizona Jackson and Earlean
Murray, as Executive of the Estate of Ruby McDonald v. Dr. Sophia Burns, M.D. 268th
District Court Fort Bend County, Texas, deposition testimony 2000
Olen Lovell III v. Texas Health Resources, Herman Methodist System, Arbitration Cause
No. 1310010565, Dallas, Texas, arbitration 1999
Walker et al v. Facility Insurance Corporation, et al, In the District Court of Travis County,
Texas 98th Judicial District, deposition testimony 1999
Milton Santiago v. American Airlines, Inc., In the 191st Judicial District Court, Dallas
County, Texas, deposition testimony 1999
Brown v. Sysco, Inc., United States District Court, Western District of Texas, deposition
testimony 1999

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Case 2:90-cv-00520-KJM-DB Document 7965 Filed 09/26/23 Page 51 of 51

Walker et al v. Facility Insurance Corporation, et al, In the District Court of Travis County,
Texas 98th Judicial District, Robinson/Daubert hearing testimony 1999
Mato v. Dr. Jack Baldauf, et.al, United States District Court, Western District of Texas,
Austin, trial testimony 1999
Goode v. City of Austin and Fine Host Corp, United States District Court, Western District of
Texas, deposition testimony 1998
Chambers v. Texas A&M et al., United States District Court, Western District of Texas,
deposition testimony 1998
Chambers v. Texas A&M et al., United States District Court, Western District of Texas, trial
testimony 1998

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