Pessano et al v. Google, Inc.

Filing 15

Transcript of Proceedings held on 9/23/11, before Judge Jeffrey S. White. Court Reporter/Transcriber Katherine Powell Sullivan, RPR, CRR, CSR, Telephone number 415-794-6659/ Per General Order No. 59 and Judicial Conference policy, this transcript may be viewed only at the Clerks Office public terminal or may be purchased through the Court Reporter/Transcriber until the deadline for the Release of Transcript Restriction.After that date it may be obtained through PACER. Any Notice of Intent to Request Redaction, if required, is due no later than 5 business days from date of this filing. Redaction Request due 11/22/2011. Redacted Transcript Deadline set for 12/2/2011. Release of Transcript Restriction set for 1/30/2012. (Sullivan, Katherine) (Filed on 11/1/2011)

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Pages 1 - 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA BEFORE THE HONORABLE JEFFREY S. WHITE IN RE GOOGLE INC., ANDROID ) CONSUMER PRIVACY LITIGATION. ) ___________________________________) ) TROY YUNCKER, individually and on ) behalf of all others similarly ) situated, ) ) Plaintiff, ) ) vs. ) ) PANDORA MEDIA, INC., ) ) Defendant. ) ___________________________________) No. M 11-2264 JSW No. C 11-3113 JSW San Francisco, California Friday September 23, 2011 TRANSCRIPT OF PROCEEDINGS APPEARANCES: For Plaintiffs: BY: BY: AUDET & PARTNERS, LLP 221 Main Street, Suite 1460 San Francisco, California 94105 WILLIAM M. AUDET, ESQUIRE JONAS P. MANN, ESQUIRE KAMBER LAW, LLC 100 Wall Street, 23rd Floor New York, New York 10005 SCOTT A. KAMBER, ESQUIRE (Appearances continued on next page) Reported By: #5812, Katherine Powell Sullivan, CSR #5812, RPR, CRR Official Reporter - U.S. District Court Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 APPEARANCES (CONTINUED): For Plaintiffs: BY: WOLF, HALDENSTEIN, ADLER, FREEMAN & HERZ, LLP 750 B Street, Suite 2770 San Diego, California 92101 BETSY C. MANIFOLD, ESQUIRE BY: LAW OFFICES OF TESFAYE W. TSADIK 1736 Franklin Street, 10th Floor Oakland, California 94612 TESFAYE W. TSADIK, ESQUIRE For Defendant Google: BY: For Defendant Pandora Media, Inc.: BY: Wilson, Sonsini, Goodrich & Rosati 650 Page Mill Road Palo Alto, California 94304-1050 MICHAEL H. RUBIN, ESQUIRE DAVID KRAMER, ESQUIRE EVAN STERN, ESQUIRE FENWICK & WEST 555 California Street, 12th Floor San Francisco, California 94104 TYLER NEWBY, ESQUIRE Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 3 1 2 P R O C E E D I N G S SEPTEMBER 23, 2011 1:27 P.M. 3 4 5 6 THE COURT: Good afternoon, everybody. Please be THE CLERK: Calling case number MDL 11-2264, In Re: seated. 7 Google Android Consumer Privacy Litigation, and case number 8 C-11-3313, Yuncker versus Pandora Media. 9 10 Counsel, please step forward to the podiums and state your appearances. 11 To the podiums, Counsel. 12 MR. KAMBER: 13 14 Thank you. Good afternoon, Your Honor. Scott Kamber on behalf of plaintiffs in King versus Google. And I'm also appearing on behalf of the plaintiffs of 15 counsel in the Urias case. They're in Texas. 16 similarly-situated interests, and they have authorized me to 17 appear on their behalf. 18 THE COURT: Welcome, sir. 19 MR. KAMBER: Thank you. 20 MR. AUDET: We have 21 THE COURT: 23 MR. TSADIK: 25 William Audet from Audet & Partners for plaintiff Levine. 22 24 Good afternoon, Your Honor. Welcome. Good afternoon, Your Honor. Tsadik appearing on behalf of Hendrick Cochran. THE COURT: Welcome. Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 Tesfaye 4 1 MR. TSADIK: Thank you. 2 MS. MANIFOLD: Good afternoon, Your Honor. Betsy 3 Manifold, Wolf Haldenstein, on behalf of Troy Yuncker in the 4 Yuncker versus Pandora case. 5 THE COURT: 6 MS. MANIFOLD: 7 MR. MANN: 8 Good afternoon. Good afternoon, Your Honor. Good afternoon, Your Honor. Jonas Mann, Audet & Partners, on behalf of the Levine plaintiffs. 9 THE COURT: Good afternoon. 10 MR. RUBIN: Good afternoon, Your Honor. Michael 11 Rubin of Wilson Sonsini for Google and all of the now 12 consolidated MDL matters against them. 13 THE COURT: Good afternoon. 14 MR. RUBIN: And my colleagues, David Kramer and Evan 16 THE COURT: Welcome. 17 MR. NEWBY: Good afternoon, Your Honor. 15 Stern. Tyler Newby 18 of Fenwick & West on behalf of Pandora in the Yuncker versus 19 Pandora matter. 20 THE COURT: Good afternoon. 21 All right. What I would like to do is go through 22 some of these agenda items, and then if there's any questions, 23 comments or arguments that anybody has to make, I'll go through 24 those. 25 The first question I have is, I assume everybody Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 5 1 received the Court's pretrial order and agenda for the initial 2 case management conference. 3 Great. So if you'll follow along with me, on page 5 4 of paragraph 12A, the discussion of interim class counsel. 5 I wondered whether you had reached a consensus concerning 6 interim class counsel? 7 8 MR. AUDET: And Your Honor, this is William Audet for the plaintiffs. 9 THE COURT: Yes. 10 MR. AUDET: I've discussed, I think, with everybody 11 who has a filed case with respect to the Google case, not the 12 Yuncker case. 13 THE COURT: Right. 14 MR. AUDET: They all have agreed that Mr. Kamber and 15 I would serve as co-lead counsel, if that was acceptable with 16 Your Honor. 17 one more follow-up, just in case I missed a lawyer. 18 I wanted to confirm that with a follow-up call, So I would like to represent to the Court that I have 19 spoken to everybody, but I'd like to speak one more time if 20 it's okay with Your Honor. 21 THE COURT: It's perfectly okay. I would like to 22 have a document, a stipulation and order to that effect. 23 in the unlikely event, from what you're saying, of there not 24 being such a consensus, then I'd like to get a briefing 25 schedule on a motion to appoint you or whoever is moving to be Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 And 6 1 interim class counsel. 2 MR. AUDET: Yes, Your Honor. 3 THE COURT: And then I would, as I mentioned in the 4 order and as the JPML rules and manuals contemplate, you would 5 then be the liaison, administratively speaking, throughout the 6 case. Is that correct? 7 MR. AUDET: Yes, Your Honor. 8 THE COURT: Very well. 9 10 good. 13 14 Well, that's So I'd like to set a deadline by which you would finalize that process. 11 12 All right. MR. AUDET: Seven days, 14 days, whatever suits Your THE COURT: Let's say two weeks. Honor. Murphy's Law might apply here. 15 MR. AUDET: Usually. 16 THE COURT: Ms. Ottolini, two weeks from today for 17 filing a stipulation for a briefing schedule with respect to 18 appointment of interim counsel, class counsel. 19 MS. MANIFOLD: 20 THE COURT: 21 MS. MANIFOLD: 22 THE COURT: 23 MS. MANIFOLD: Your Honor, Betsy Manifold. Yes. May I be heard? Yes, of course. On behalf of the Pandora case, the 24 Yuncker versus Pandora case, my understanding is that interim 25 counsel would not cover that case. There's no overlapping Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 7 1 parties. 2 There's no similarity in class. We're the only counsel in the Yuncker case. So I 3 don't know that it would be necessary to appoint interim 4 counsel separately for the Pandora case. 5 THE COURT: I think you're right. I don't anticipate 6 that will be the case. 7 into some of the nitty-gritty here, I intend to run the cases 8 in parallel, for the moment. 9 Although, as you'll hear when we get I don't know -- unless you, Counsel, have a different 10 view -- that that's inappropriate. 11 cases together artificially. 12 I don't want to jam two just schedule-wise. But I'd like to run them together 13 Is that acceptable to you? 14 MR. AUDET: 15 Yes, Your Honor. William Audet speaking for plaintiffs. 16 THE COURT: Yes. 17 MR. AUDET: Yes, Your Honor. 18 THE COURT: Okay. 19 MS. MANIFOLD: 20 And that's acceptable, also. Betty Manifold on behalf of Yuncker plaintiffs. 21 22 Great. We've conferred and we now agree that they should be on parallel tracks. 23 THE COURT: 24 right. 25 the Pandora case. Great. Well, good. That's good. All So your stipulation and order does not need to cover Okay. Great. Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 8 1 Now -- 2 THE CLERK: Do you want a date set? 3 THE COURT: Yes. 4 THE CLERK: October 7th will be the date that will be THE COURT: All right. 5 I'm sorry. due. 6 Now, the next item I'd like 7 to discuss is the item on page 7, which was 12E, the protective 8 order. 9 discuss the stipulated protective order. 10 And I'm directing that counsel should be prepared to And, as you know, there's one that's recommended on 11 the Court's website. 12 this kind of case. 13 14 It might need to be modified because of What could the parties report with respect to that paragraph? 15 MR. AUDET: Your Honor, I had a meet-and-confer 16 yesterday with Mr. Rubin, counsel for Google, and we discussed 17 either using the model. 18 similar to the model, Your Honor. 19 that. 20 week or two weeks. 21 22 And Google may, in fact, have one And we may just provide We will go over it and provide it to Your Honor within a THE COURT: All right. Let's make it the same day, Ms. Ottolini. 23 THE CLERK: October 7? 24 THE COURT: Yes. 25 Now, item F on page 7. Settlement and ADR. Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 So, now, 9 1 obviously, we'll have interim class counsel appointed, 2 probably, in two weeks, and then the filing of the consolidated 3 master class action complaint. 4 5 So have the parties talked about possible settlement discussions or ADR? 6 MR. AUDET: Your Honor, again, I had another 7 discussion yesterday. 8 including that item. 9 obviously need to wait for appointment of lead counsel. 10 We went over all your agenda items, In going through, we mentioned we And then they mentioned -- Mr. Rubin, speak for 11 yourself -- that they don't want to do ADR. 12 But there's a particular position -- 13 MR. RUBIN: Michael Rubin for Google. 14 THE COURT: Yes. 15 MR. RUBIN: Our view, at this point, is that 16 mediation is likely to be the most effective, but that waiting 17 until after a definitive ruling on the anticipated motion to 18 dismiss makes the most sense. 19 complaint, if there is one, will be the logical time to do 20 that. 21 THE COURT: And until we have a fixed All right. Well, I think that's fair. 22 The parties should continue to keep that in mind. 23 anticipate doing, certainly no later than in the time of ruling 24 on the motion to dismiss the master -- the anticipated motion 25 to dismiss the master complaint would be to set -- discuss Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 But what I 10 1 further deadlines for mediation, either private mediation or 2 under the auspices of the Court's ADR program. 3 be thinking about which you prefer. 4 And you should I think you're right that a mediation initially would 5 be better than a magistrate judge because a magistrate judge 6 wouldn't have as much time as a mediator would. 7 just advise you that the Court is going to be keenly interested 8 in keeping that track open, not go too far down the path here 9 as far as, you know, expenditure of resources before getting to 10 11 But I will that point. Now, item G, scheduling. Obviously, the class 12 certification motion will occur, will be filed after 13 adjudication of the motion to dismiss. 14 15 16 So what have the parties discussed about as far as class certification motions? MR. AUDET: Your Honor, we did have a discussion. 17 think we put it in our prior CMC. 18 I it was six months. 19 20 MR. RUBIN: I'm speaking now -- I think I believe that the -- this is Michael Rubin for Google. 21 THE COURT: Yes. 22 MR. RUBIN: The agreement was that we file as early 23 as practical, although there was no agreement on a specific 24 time frame. 25 negotiated and the stipulation provided to the Court. And the specific briefing schedule will be Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 11 1 THE COURT: All right. How soon? 2 MR. RUBIN: It's not something that we can determine 3 as the defendants. 4 would be done as soon as practical. 5 It's up to the plaintiffs. But we hope it Frankly, Your Honor, until there's a fixed complaint, 6 we're not sure whether there's any purpose in detailing a 7 specific date. 8 listen. 9 But if they have one in mind, we're happy to MR. AUDET: Your Honor, my view is we can probably 10 get -- as long as we get some discovery from the defendants 11 that will help us for class certification purposes, we can file 12 a class cert within six months of when the Court rules on the 13 motion to dismiss. 14 15 THE COURT: Well, I think that's fair. Is that acceptable with you? 16 17 Okay. So six months from -- and the date will be set forth in the Court's order on the motion to dismiss. 18 MR. RUBIN: 19 that. 20 Yes, Your Honor. We have no objection to And my understanding is that will track the close of fact discovery. 21 THE COURT: 22 Okay. Correct. Let's see. Yes. That's correct. All right. I want to -- the other 23 items I think were pretty clearly set forth in the Court's 24 order. 25 management conference statement. And, also, counsel did a good job in the case Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 12 1 I want to go over some -- before I ask for general 2 comments or any other matters that you all want to bring up, 3 generally speaking -- and we've now established through the 4 Pandora plaintiffs that the parties are willing there to stick 5 to the same schedule that has been proposed in the Google 6 matter. 7 8 Is that correct? MS. MANIFOLD: of the Pandora matter. Your Honor, Betsy Manifold on behalf That's correct. 9 And I also wanted to indicate that I have been 10 listening to the schedule set in the Google case, and we 11 certainly agree with the six months with regard to the class 12 cert motion. 13 And we had a similar discussion with regard to ADR 14 with the Pandora defendants, and it went along almost the exact 15 same track that was recited here between the Google plaintiffs 16 and Google. 17 So to the extent there's any differences, I would 18 raise them with the Court. So far the scheduling has been 19 acceptable, and we're willing to track as far as the scheduling 20 has proceeded, at this point. 21 THE COURT: Right. And appreciate that. And one of 22 the earliest things that will happen is, I'm assuming, and this 23 is confirmed by the stipulation that was entered into -- that 24 particularly an anticipated motion to dismiss in the Pandora 25 case would be briefed and heard on the same day, same track, Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 13 1 and the hearing would be on the same day. 2 3 MS. MANIFOLD: Your Honor, Betsy Manifold. Yes, we agree on behalf of Pandora plaintiffs. 4 THE COURT: 5 objection to that? 6 Okay. Great. And I assume Google has no fight. 7 I guess you didn't have a dog in that MR. RUBIN: This is Mike Rubin for Google. To the 8 extent we have a dog in that fight, we have no objection. 9 That's what our proposal was. 10 THE COURT: 11 So, again, I won't need to go through some of these All right. Very well. Okay. 12 items that I had noted in preparing with respect to, for 13 example, on page -- on page 6 of the case management statement 14 in the Pandora case, where there's a recommendation -- Google 15 recommends scheduling responsive pleadings on case in parallel. 16 We've discussed that. 17 parallel to the Google pleading schedule. 18 That will be the case. It will run Same is true on initial -- the stay of initial 19 disclosures reflected on page 7, starting on line 2. 20 disclosures being stayed until after the Court rules on 21 Pandora's anticipated responsive pleading. 22 due 30 days following the date on which the pleadings in the 23 action become fixed. 24 schedule there specifically. 25 Initial And it should be And we'll follow, again, the Google With respect to -- on page 7, line 14, the Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 14 1 defendants' position with respect to the stay of discovery 2 until after resolution of responsive pleading to the complaint, 3 the Court accepts that. 4 discovery as proposed in that regard. That's -- we are going to stay All right. 5 Similarly, page 8, at line -- starting at line 7, 6 where you're discussing both the protective order and Bates 7 numbering systems used in one proceeding acceptable on 8 materials cross-produced in another, the Court accepts that as 9 well. 10 I think that's a good way to proceed. And whatever -- with respect to class actions item 11 number 9, line 17 on page 8, whatever schedule is worked out in 12 the Google case will be followed in connection with the Pandora 13 case, as well. 14 All right. Well, those were all the matters that the 15 Court had on its agenda, because you all did an excellent job 16 of preparing this and I was able to help you out with the 17 Court's order. 18 Are there any other matters? I think we have the 19 scheduling pretty well fleshed out, at least the first piece of 20 this case pretty well on a good track. 21 So anybody have any comments? 22 MR. AUDET: 23 Does Your Honor want to set another CMC? 24 THE COURT: 25 Questions? Concerns? For plaintiffs, we don't have any. Yes. I'm going to do that. What would counsel propose -- not necessarily a specific date, but in Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 15 1 terms of -- what I'd like to do in a case like this, I always 2 do it as tied to an event. 3 So I'd like to hear from counsel about what event you 4 think would be appropriate, because what I would anticipate at 5 the next CMC would be getting a supplemental statement telling 6 me what you've done since we last met, and do we need to change 7 the schedule, and kind of where do we go in the next phase of 8 the case. 9 10 11 So, I'll start with plaintiffs and then I'll ask defense counsel. MR. AUDET: Your Honor, normally I would say just tie 12 it to the motion to dismiss, but I think, actually, what I 13 would recommend is it might save a little resources if people 14 filing something that says we haven't done anything but the 15 motion to dismiss, is maybe a hearing that's tied to Your Honor 16 actually -- hopefully not denying the motion to dismiss -- 17 (Laughter) 18 THE COURT: 19 (Laughter) 20 MR. AUDET: 21 So that was my thinking, because in the past, when Hope springs eternal, right? Ever the optimist. 22 we've been before Your Honor we tell you at our CMCs, all we've 23 done is a motion to dismiss. 24 25 THE COURT: Right. And that's not very satisfying. So I think what I'll do is, rather than set a date now, I'll Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 16 1 set a date in the first substantive order the Court issues. 2 And then if anybody thinks -- wants to come back or you want to 3 come back with a stipulation and order saying there's really 4 nothing to report, we propose maybe waiting until, you know, 5 whatever -- it depends on the outcome, obviously. 6 But, you know, one alternative is such a motion is 7 denied completely. 8 the third is it's granted without leave. 9 One is that it's granted with leave. And If it's granted without leave, then it's the Ninth 10 Circuit's problem, at that point, or whatever Circuit you all 11 go to. 12 will set that in the next order. But let's not cross that bridge at this point. And I 13 All right. Anything further the parties wish to -- 14 MR. NEWBY: Yes, Your Honor. This is Tyler Newby for 15 Pandora. 16 speak incorrectly, but we've met and conferred with the 17 plaintiffs in our case, and there may be an amendment to the 18 complaint in their case. 19 And I invite counsel for Yuncker to correct me if I We would just suggest that that amendment, if there 20 is one, to the complaint be along the same schedule as 21 Google's -- as the filing of the consolidated complaint in the 22 Google matter. 23 THE COURT: 24 MS. MANIFOLD: 25 Pandora. Yes. Is that acceptable? Betsy Manifold on behalf of the I'm glad you clarified. That's what I had Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 17 1 assumed, we would file an amended complaint to concur with the 2 Google amended complaint, but yes, I agree. 3 THE COURT: All right. So I assume, to the extent 4 that that complaint is not as a matter of right, that there 5 would be a stipulation. 6 they're usually a waste of time. 7 case is, that that would be -- that would be acceptable. 8 9 10 I don't like Rule 15 motions because And I assume, given where the So would your amended complaint -- would you contend it's of right? MS. MANIFOLD: The complaint has not been amended and 11 there's been no responsive pleadings, so I would contend it is 12 as of right. 13 THE COURT: All right. Great. Then we don't have to 14 worry about that. 15 down no later than the time of the filing of the consolidated 16 complaint in the Google case. 17 for motions to dismiss in both cases, and then the Court can 18 run those in parallel. 19 And I would expect the amendment to come That way that'll track very well One thing I wanted to say for no -- no reason other 20 than it's sort of like an elephant in the room, the Court is 21 aware that there have been recent decisions in similar cases -- 22 in the Apple case and in the Facebook or Twitter, the one 23 before Judge Seeborg. 24 those cases. 25 And so I'm assuming counsel are aware of Again, I haven't, quite honestly, read them yet. Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 I 18 1 just read an article that they existed. 2 read them at some point. 3 I'm not even sure they apply, but seem to be similar cases 4 alleging involved invasion of privacy and the like. 5 And I'll attempt to But I think counsel should be aware. And I assume that counsel will be giving those both 6 in terms of their pleadings and in terms of their motions. 7 necessarily does the Court find it would be bound by those 8 decisions. 9 the same ballpark. 10 Not I don't know what they say, but they seem to be in And I want counsel to familiarize themselves with those decisions. 11 So, anything else from the plaintiff's perspective? 12 MR. AUDET: 13 Speaking for plaintiffs, William Audet, no, Your Honor. 14 THE COURT: All right. From the defendants? 15 MR. RUBIN: Nothing further, Your Honor. 16 The only note I'll make is we believe October 7, 17 which is two weeks from today, is the date we can strive to hit 18 for a proposed protective order. 19 going to actually occur for many months, it may be additional 20 time will be needed. 21 a stipulation. 22 THE COURT: Given that discovery is not If there will, I would propose we submit Fair enough. And, certainly, this is 23 good cause. You know, I'm pretty strict on dates, but in an 24 MDL case like this, I don't want my strictness to be the tail 25 that wags the dog here. Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 19 1 So if you can stipulate to a reasonable extension, I 2 certainly would grant that, because my goal is to keep 3 everybody's feet to the fire. 4 burner because it's going to be on my front burner, as I do 5 with all these cases. 6 goal of parallelism, so we don't waste resources here and can 7 run these cases in parallel. 8 Perfectly okay. 9 MR. RUBIN: Keep this case on your front And also to make sure nothing upsets the But subject to that, absolutely. Your Honor, I understand. With the goal 10 of parallelism, I'll say that coordinating a protective order 11 that will cover both the Yuncker and Google MDL may be a bit 12 more complicated than a standard protective order. 13 THE COURT: Fair point. 14 All right. Anything further? 15 MR. RUBIN: Nothing further from Google. 16 THE COURT: All right. Thank you. You all so far 17 have done an excellent job and the Court appreciates your 18 cooperation in working with the Court. 19 (Counsel simultaneously thank the Court.) 20 (At 1:48 p.m. the proceedings were adjourned.) 21 - - - - 22 23 24 25 Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659 1 2 CERTIFICATE OF REPORTER 3 4 I certify that the foregoing is a correct transcript from the record of proceedings in the above-entitled matter. 5 6 DATE: Tuesday, November 1, 2011 7 8 s/b Katherine Powell Sullivan _________________________________ 9 Katherine Powell Sullivan, CSR #5812, RPR, CRR U.S. Court Reporter 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Katherine Powell Sullivan, CSR, RPR,CRR Official Reporter - U.S. District Court (415) 794-6659

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