National Federation of the Blind et al v. Target Corporation

Filing 49

ERRATA re 42 Reply to Opposition to Motion for Preliminary Injunction by National Federation of the Blind, Bruce Frank Sexton, the National Federation of the Blind of California, National Federation of the Blind, Bruce Frank Sexton, the National Federation of the Blind of California. (Attachments: # 1 # 2 # 3 # 4 # 5)(Paradis, Laurence) (Filed on 7/14/2006)

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National Federation of the Blind et al v. Target Corporation Doc. 49 Att. 5 Case 3:06-cv-01802-MHP Document 49-6 Filed 07/14/2006 Page 1 of 7 EXHIBIT 14 Dockets.Justia.com Case 3:06-cv-01802-MHP Document 49-6 Filed 07/14/2006 Page 2 of 7 1 2 3 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) 4 NATIONAL FEDERATION OF THE BLIND, ) 5 the NATIONAL FEDERATION OF THE 6 BLIND OF CALIFORNIA, on behalf of ) 7 their members, and Bruce F. Sexton,) 8 on behalf of himself and all others) 9 similarly situated, 10 11 V. 12 14 15 16 17 18 19 20 21 22 ATKINSON-BAKER, INC. COURT REPORTERS 23 (800) 288-3376 www.depo.com 24 FILE NO.: A00554A 25 REPORTED BY: TERESA IDEN, CCR NO. 646 1 ) ) ) DEFENDANT ) ) NO. C06-01802 MHP PLAINTIFFS ) 13 TARGET CORPORATION, ORAL DEPOSITION OF DAVID HENRY WILKINSON TAKEN IN LITTLE ROCK, ARKANSAS JUNE 21, 2006 Case 3:06-cv-01802-MHP Document 49-6 Filed 07/14/2006 Page 3 of 7 1 part of what I marketed was training. And as a result 2 of that, we were interested to see how people were using 3 the Internet to conduct training seminars. And as a 4 result of that, I was enrolled in an HTML course, 5 basically to see how it worked, how stable the 6 environment was to see if a class, at that point in 7 time, could be effectively conducted over the Internet. 8Q And what was the -- your feeling about that 9 afterwards? I mean, what -- what did you gain from this 10 experience? 11 A 12 Q 13 A I'm frankly not sure if I gained much of anything. Okay. I saw it work, and I saw it crash a lot. And it 14 convinced me that, at that point, it wasn't something 15 that we should be pursuing until technology caught up 16 with the concept a bit more. 17 Q Okay. Beginning -- can you please describe your 18 job history, beginning with your current job and going 19 backwards? 20 A I currently am a Low Vision Consultant for Easter 21 Seals of Arkansas. I also am an Assistive Technology 22 Consultant. I do a number of different little projects 23 here and there and everywhere. Before that, I was a 24 Sales Manager for Freedom Scientific. I'm sorry, I 25 skipped a job. I was an Assistive Technology Instructor 11 Case 3:06-cv-01802-MHP Document 49-6 Filed 07/14/2006 Page 4 of 7 1 at Lion's World Services for the Blind in Little Rock, 2 which is a vocational rehabilitation center. Before 3 that, I was a Sales Manager at Freedom Scientific. 4 Before that, I was a Sales Manager for Bartemaes Group, 5 and I was a Sales Manager and the entire sales force. 6 Before that, I was a Residence Hall Director at American 7 University with a building of several hundred freshman 8 and sophomores under my leadership and guidance. 9 Previous to that, I was a Residence Hall Director at 10 Salem State College in Salem, Massachusetts. The same 11 type of position, but a smaller school, state-run 12 instead of private. Continuing backwards, now we're to 13 the college years. I had an internship in the Program 14 Office at the New York University Office of Student -15 Center for Student Activities or whatever it was called, 16 where we planned a lot of events that were brought onto 17 campus and satisfied the entertainers, negotiated the 18 contracts, etcetera. I had a position as a desk clerk 19 as I worked my way through my undergrad degree. I have 20 tuned pianos. I have worked in a music library. And 21 I've worked in a photocopy shop. And I've probably left 22 something out in there. I also brailed texts for a 23 deaf/blind individual while at NYU, for a couple of 24 years. 25 Q Okay. Can you give me the dates for these jobs? 12 Case 3:06-cv-01802-MHP Document 49-6 Filed 07/14/2006 Page 5 of 7 1 who wasn't home and whom I wouldn't have asked anyway. 2 The point was, I wanted to look around the website and 3 see what I could find, so I did. 4Q Okay. You say in your declaration that you 5 encountered obstacles on target.com. Do you recall what 6 those obstacles were? 7 A Certainly a link that doesn't tell me where it's 8 going to go is a barrier to being able to get there. I 9 also -- well, I'm trying to think if that's -- that's 10 Target-specific. I think that it would be great if 11 those links -- I mean, if that -- if -- I'm -- and it 12 would be nice if they were labeled specifically. Could 13 it be probably designed a bit better? Okay. But it 14 certainly didn't keep me from using the site. 15 16 17 18 19 20 21 22 23 24 25 MR. BASRAWI: I'm sorry. Can you read back that last answer, please? COURT REPORTER: Answer, "Certainly the link that doesn't tell me where it goes is a barrier to being able to get there. I also know -- I'm trying to think if those are Target-specific. And it would be great if those links -- it would be nice if they were labeled. Could it be designed a bit better? Okay. As for that, it didn't keep me from using the site." 84 Case 3:06-cv-01802-MHP Document 49-6 Filed 07/14/2006 Page 6 of 7 1 2 3 4 5 6 7 9Q please. MR. PLUNKETT: Okay. (WHEREUPON, a short break was taken, after which deposition proceedings resumed as follows, to-wit:) MR. BASRAWI: Okay. Back on the record? COURT REPORTER: Yes. Mr. Wilkinson, I have a couple more questions. 8 BY MR. BASRAWI: 10 One. How long did it take you to get to your current 11 level of proficiency with screen reader use? 12 14 A MR. PLUNKETT: Objection. Vague. I'm frankly not sure. I've been using screen 13 BY THE WITNESS: 15 readers, as you know, for quite a long time, but I'm -16 I'm not really sure. It's been an ongoing -- it's been 17 an ongoing process. 18 BY MR. BASRAWI: 19 Q Okay. Do you know how long it would take someone 20 who is just starting to learn how to use a screen reader 21 -- how long to get to your level of proficiency? 22 23 25 A MR. PLUNKETT: Objection. Vague. Calls for speculation. I'm frankly not sure what my level of proficiency 116 24 BY THE WITNESS: Case 3:06-cv-01802-MHP Document 49-6 Filed 07/14/2006 Page 7 of 7 1A I'm not sure what my level of proficiency is. I 2 believe they've reached -- I believe that some people, 3 in varying degrees of time, depending on their interest, 4 ability, and willingness to work at it, will be able to 5 get to where they need to be, using a computer. 6Q Do you believe that someone who's learning, who 7 took several weeks or months to learn how to use a 8 screen reader for the first time, is qualified to be a 9 consultant in access technologies? 10 11 13 A MR. PLUNKETT: Objection. Incomplete hypothetical. Vague. Calls for speculation. I believe we established earlier that I have more 12 BY THE WITNESS: 14 of a breadth of knowledge of specific devices that may 15 be useful than someone who is going through classes and 16 learning how to use -- how to use a screen reader. 17 18 19 20 21 22 23 24 25 118 MR. BASRAWI: Okay. No further questions. (WHEREUPON, there being no further questions the deposition concluded at 12:15 p.m.) *********** WITNESS EXCUSED

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