O'Bannon, Jr. v. National Collegiate Athletic Association et al

Filing 237

Administrative Motion to File Under Seal Defendant NCAA's Deposition Designations filed by National Collegiate Athletic Association. (Attachments: # 1 Declaration of Jeslyn A. Miller, # 2 Proposed Order, # 3 NCAA's Deposition Designations, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Exhibit K, # 15 Exhibit L, # 16 Exhibit M, # 17 Exhibit N, # 18 Exhibit O, # 19 Exhibit P, # 20 Exhibit Q, # 21 Exhibit R, # 22 Exhibit S, # 23 Exhibit T, # 24 Exhibit U, # 25 Exhibit V - REDACTED, # 26 Exhibit V - SEALED, # 27 Exhibit W, # 28 Exhibit X, # 29 Exhibit Y, # 30 Exhibit Z, # 31 Exhibit AA, # 32 Exhibit BB)(Miller, Jeslyn) (Filed on 6/23/2014) Modified on 6/24/2014 (kcS, COURT STAFF).

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EXHIBIT I In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION in re NCAA Student-Athlete Name and Likeness Licensing Litigation Case No. 09-cv-1967-CW * MAY CONTAIN CONFIDENTIAL INFORMATION * - - VIDEOTAPED DEPOSITION OF THAD JARACZ NOVEMBER 30, 2011 9:00 A.M. KILPATRICK TOWNSEND & STOCKTON LLP 1100 PEACHTREE STREET, SUITE 2800 ATLANTA, GEORGIA REPORTED BY: STEVEN S. HUSEBY, RPR CCR-B-1372 Designation Color Key Blue = NCAA Affirm Desigs. Orange = Pls' Counter Desigs. Fuchsia = NCAA Rebuttal Desigs REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 7 1 MR. SLAUGHTER: James Slaughter, 2 Keker & Van Nest, on behalf of Electronic 3 Arts. 4 MR. BOARDMAN: Thomas Boardman, 5 Pearson, Simon, Warshaw & Penny. 6 I represent the antitrust plaintiffs. 7 MR. CLOBES: 8 Cafferty Faucher, for the plaintiffs. 9 10 MS. BASS: Bryan Clobes, Camille Bass, from Hagens Berman, representing plaintiffs. 11 THAD JARACZ, 12 being first duly sworn, was examined and 13 testified as follows: 14 15 EXAMINATION BY MR. CURTNER: 16 Q. Good morning, sir. 17 A. Good morning. 18 Q. Would you state for the record your 19 full name, please? 20 A. Thad Jaracz. 21 Q. Where do you live, Mr. Jaracz? 22 A. I live in Crestwood, Kentucky. 23 Q. And what is the address? 24 A. 4001 Bowen Circle, Crestwood, 25 Kentucky, 40014. REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 9 1 Louisville for awhile? 2 A. I was. 3 Q. And was that prior to West Texas? 4 A. No, when I came from San Antonio in 5 1986 to Louisville, I was the professor of 6 military science at the University of 7 Louisville. 8 9 Q. So now I've interrupted the train here, so where did you reside before Texas? 10 A. Before which time? 11 Q. Well, let's see, you were in Europe 12 and then Texas. 13 time. 14 A. I'm just trying to go back in So before your first time in Texas? I have to think. It's been a long 15 time. 16 to Texas the first time in 1976 to the West 17 Texas State University. 18 assignment I was in Fort Knox, Kentucky and 19 doing work at the armory school doing some 20 work there. 21 22 Q. I have to think this through. I went Prior to that And you graduated from the University of Kentucky? 23 A. I did. 24 Q. With a degree in what? 25 A. Political science. REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 10 1 Q. And what year did you graduate? 2 A. 1976. 3 Q. '76? 4 A. 1976. 5 Q. Okay. 6 that, correct, when you played basketball? 7 8 9 But you played earlier than A. I played basketball earlier than that, Q. So what did you -- if I understand yes. 10 correctly, you played basketball during the 11 '60s? 12 A. I arrived in 1964 and I left in 1968. 13 Q. So you did not finish your degree 14 while you were there but you finished your 15 degree later. 16 17 18 A. Is that accurate? I completed my degree after I entered the military. Q. I see. So you left Kentucky in 1966 19 and if I understand correctly you were drafted 20 by the Boston Celtics in the NBA draft; is 21 that right? 22 A. No. 23 Q. '68, I'm sorry. 24 A. And I was drafted by the Celtics that 25 I left Kentucky in 1968. fall. REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 11 1 Q. And if I understand correctly you had 2 a tryout or a time with the Celtics but then 3 didn't make the team and they asked you to go 4 on a backup team or some other alternate team 5 and you did that for awhile and then you were 6 drafted. Is that accurate? 7 A. No. 8 Q. I should ask, or let you answer. 9 A. What is the question? 10 Q. Why don't you tell me what you did 11 12 after you left Kentucky in 1968. A. I was drafted by the Celtics, I was 13 cut by the Celtics, I was drafted by the Army, 14 and that's what happened after I left 15 Kentucky. 16 17 Q. Okay. When you were with the Celtics, did you have a contract? 18 A. No. 19 Q. So you were trying out for a contract 20 and never got one? 21 A. That's true, yes. 22 Q. Were you ever a member of the NBA 23 Players Association? 24 A. No. 25 Q. Was there a player's association in REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 51 1 the media has portrayed the game over time as 2 being different from what it was at the time? 3 A. Yes. 4 Q. Do you own a copy of this book? 5 A. Yes. 6 Q. So it's on your bookshelf at home? 7 A. Yes. 8 Q. You agreed to be interviewed for this 9 10 and allow your name to be used and your words to be used? 11 A. Yes. 12 Q. Did you get paid for that? 13 A. No. 14 Q. Did you ask to be paid? 15 A. No. 16 Q. So you realize that you were a 17 participant in an event of historical 18 significance; is that right? 19 A. No. 20 Q. Do you agree that that 1966 21 championship game was at the time and has 22 become more so an event of historical 23 significance? 24 25 A. In terms of historical significance, I thought you were talking about this book. REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 52 1 2 Q. I was. But I'm now asking a different question, I'm asking about the game. 3 CC 701 A. So the question is then? 4 Q. Do you agree that it was a 5 historically significant event? 6 A. I do agree. 7 Q. And it would have been a historically 8 significant events even if it was just a NCAA 9 championship final game, right? 10 games are of some significance? All those 11 A. To certain people. 12 Q. Certainly to people who played in them 13 14 or watched them or rooted for them, right? A. They're certainly significant -- 15 MR. CLOBES: 16 THE WITNESS: 17 -- for those that played in them. 18 Objection, form. BY MR. CURTNER: 19 Q. And this game, because of the way it's 20 been portrayed over history has taken on a 21 special significance. 22 that? You would agree with 23 MR. CLOBES: 24 THE WITNESS: 25 Objection to form. Yes, I would agree with that. REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 53 1 CC 701 2 BY MR. CURTNER: Q. And that you as a player on one of 3 those teams were a participant in an event of 4 historical significance, correct? 5 A. Yes. 6 Q. And that makes your participation a 7 subject of legitimate public interest, 8 correct? 9 MR. CLOBES: 10 11 12 THE WITNESS: Objection, form. Yes. BY MR. CURTNER: Q. I mean, people can reasonably be 13 curious about the first game where there was 14 and all-black team against an all-white team 15 and whether it was about race or whether it 16 was about basketball. 17 legitimate public issues, correct? Those are all 18 MR. CLOBES: 19 THE WITNESS: 20 21 Objection, form. Yes. BY MR. CURTNER: Q. And so you don't think that somebody 22 needs your permission to write about that game 23 or talk about that game or show photographs of 24 that game, do you? 25 MR. BOARDMAN: Objection, form. REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 54 1 MR. CURTNER: 2 3 down. 4 CC 701 were going to do that. I was afraid you BY MR. CURTNER: 5 Q. Okay, I'll break it You agree that it's a matter of 6 legitimate public interest and significance, 7 right? 8 A. The game in 1966? 9 Q. Yes, sir. 10 A. Yes. 11 Q. And you agree that your participation 12 in it thereby becomes a matter of legitimate 13 public interest, correct? 14 MR. CLOBES: 15 THE WITNESS: 16 You're talking about my personal participation? 17 Objection, form. BY MR. CURTNER: 18 Q. Yes, sir. 19 A. Yes. 20 Q. You were there, right? 21 That makes you a semi-famous person, right? 22 A. I was there, yes. 23 Q. And so it's likewise legitimate public 24 interest for somebody to write books or 25 articles or other pieces or to speak on TV REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 55 CC 701 1 about that event of public significance, 2 correct? 3 MR. CLOBES: 4 THE WITNESS: 5 6 7 Q. And the same is true of showing photographs from that event? MR. CLOBES: 9 THE WITNESS: 11 12 Yes. BY MR. CURTNER: 8 10 Objection to form. Same objection. Yes. BY MR. CURTNER: Q. And the same is true of showing videotape from that event? 13 MR. CLOBES: 14 THE WITNESS: Same objection. I have no knowledge 15 of that. 16 exactly what you're trying to ask me here. 17 BY MR. CURTNER: 18 Q. I mean, I don't really understand Well, that's my job, you know, but let 19 me try it this way. You would agree that 20 people have a legitimate public interest in 21 that game and what it was really about as well 22 as what it has come to be portrayed as, right? 23 MR. CLOBES: 24 THE WITNESS: 25 Objection to form. I don't understand -- I don't understand the "what it REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 56 1 was really about" part of the question. 2 BY MR. CURTNER: 3 Q. Okay, that there's a legitimate public 4 interest in understanding that game or knowing 5 about that game? 6 MR. CLOBES: 7 THE WITNESS: Objection to form. What the game was 8 about was the national championship game 9 between two teams to try to win the national 10 championship. 11 that we're discussing are parts that I 12 basically have no knowledge of. 13 what I have personal knowledge of is in the 14 game itself at the time. 15 BY MR. CURTNER: 16 Q. The other public interest parts You know, But because it has taken on this 17 greater significance in the minds of a lot of 18 people, if not -- but not in your mind, you 19 agree that people have a legitimate interest 20 in understanding that game, right? 21 MR. CLOBES: 22 THE WITNESS: Objection to form. I understand 23 legitimate interest in the game, yes. 24 BY MR. CURTNER: 25 Q. Is it accurate that at the time that REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 69 1 of news articles and, you know, things like 2 that from the local papers while I was at the 3 university. 4 Q. And do you still have those things? 5 A. I do. 6 Q. What about jerseys or other 7 memorabilia, programs, photos, things like 8 that, do you have any of those? 9 A. No jerseys. I have one or two 10 programs that were of the period, I think, 11 that were autographed and those kind of 12 things. 13 Q. I take it that you think that you've 14 been pretty fortunate in your career in the 15 military and in business since then; is that 16 right? 17 A. Yes. 18 Q. You feel like you've had a successful 19 life? 20 A. Yes. 21 Q. And do you attribute some of that to 22 the education and the background that you got 23 while you were at Kentucky? 24 A. Yes. 25 Q. Were you a scholarship player? REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 70 1 A. Yes. 2 Q. So you went to Kentucky on an athletic 3 Grant-in-Aid? 4 A. Yes. 5 Q. Did you get a full scholarship? 6 A. Yes. 7 Q. Were you recruited by Coach Rupp? 8 A. Yes. 9 Q. Where did you go to high school? 10 A. Lexington Lafayette. 11 Q. And were you recruited by other 12 schools and teams? 13 A. Yes. 14 Q. Who else? 15 A. It's been a long time ago. 16 Q. I was an undergrad at the same time so 17 I -- you and I are the same vintage. 18 Michigan. 19 was there, I remember. 20 A. I was at You guys beat Cazzie Russell when I Wonderful game. I believe I had at 21 least letters and other kinds of initial -- 22 you know, we know who you are kinds of things 23 from 40 or so schools. 24 25 Q. Did you make -- did they have official visits back in those days? I don't remember. REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 73 1 A. I don't remember signing anything. 2 Q. Do you remember any forms that you 3 signed in connection with enrolling or playing 4 basketball at Kentucky? 5 A. I don't remember any forms. 6 Q. Do you remember signing anything in 7 8 connection with your scholarship? A. No. 9 10 MR. CLOBES: remember? 11 12 13 No, you don't THE WITNESS: I don't remember. BY MR. CURTNER: Q. Did you get something every year that 14 said we hereby award you a scholarship for the 15 upcoming academic year? 16 A. I don't remember. 17 Q. And I take it you didn't save any of 18 that sort of stuff? 19 A. No. 20 Q. When you played in high school, were 21 your games covered by the local press? 22 A. Yes. 23 Q. Did your photographs of your games get 24 25 included in the newspaper? A. Yes. REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 121 1 different than it used to be; is that 2 accurate? 3 A. Parts of it I think are a lot -- a lot 4 different. 5 Q. So but isn't it also true that what 6 the student athlete, the sort of support they 7 get from the school has also changed 8 dramatically over time? 9 A. In terms of? 10 Q. Well, they get tutors, they get 11 amazing facilities, they get strength coaches, 12 they get conditioning coaches, you know, they 13 get all kinds of support that back in your day 14 people didn't get. Isn't that true? 15 MR. CLOBES: 16 THE WITNESS: Objection, form. I think there are 17 more resources today than there were when I 18 played. 19 BY MR. CURTNER: 20 21 Q. And people didn't get Pell grants back in your day either, did they? 22 A. I don't know. 23 Q. Do you know what a Pell grant is? 24 A. No. 25 Q. Do you know that current players if REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 126 1 A. No. 2 Q. Did you talk to Pam Vaccaro? 3 A. She called me I'm going to say once or 4 twice but I don't remember if it was -- I 5 don't remember when in the timeline. 6 Q. Anybody else? 7 A. No. 8 Q. Do you know who Ramogi Huma is? 9 A. No. 10 Q. Do you know what the National College 11 Players Association is? 12 A. No. 13 Q. Have you seen any of their literature 14 or their petitions? 15 A. No. 16 Q. Do you think college basketball and 17 football players should be unionized? 18 A. No. 19 Q. Do you think they should be employees 20 of their university? 21 A. No. 22 Q. Do you think they should be students 23 first and athletes second? 24 MR. CLOBES: 25 THE WITNESS: Objection to form. Yes. REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 146 1 A. No, but the people that are asking for 2 the autographs are -- are individuals to the 3 best of my knowledge that are, you know, 4 personal use kinds of stuff. 5 Q. Is there anything stopping you or has 6 there been to your mind, anything stopping you 7 over the years from saying I'd be happy to do 8 that but I need five bucks or ten bucks or 500 9 bucks? 10 A. No. 11 Q. In other words, you weren't prohibited 12 by anything you agreed to while you were a 13 student athlete from getting paid for giving 14 your photo or your autograph after you stopped 15 being a student athlete, correct? 16 MR. BOARDMAN: 17 THE WITNESS: 18 19 Objection, form. No. BY MR. CURTNER: Q. Just to be clear, you were not 20 prohibited from getting paid for doing those 21 sorts of things, correct? 22 MR. BOARDMAN: 23 THE WITNESS: 24 25 Same objection. No. BY MR. CURTNER: Q. You thought you were prohibited? We REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 185 1 a long successful involvement in a sport like 2 Kentucky in basketball, but not so much in 3 football, should not get the benefit of that 4 long success? 5 MR. CLOBES: 6 THE WITNESS: Objection, form. I think they are 7 already getting the benefit of that long 8 success. 9 potentially discussing, my concept would be 10 And I think the benefit that we're that it would be distributed fairly, equally. 11 MR. CURTNER: I think I'm done. 12 just want to check one thing here. 13 I BY MR. CURTNER: 14 15 Q. You were the captain of the team in the '65/'66 season at Kentucky? 16 A. No. 17 Q. Oh, you were team captain in '68, I'm 18 sorry; is that correct? 19 A. Yes, yes. 20 Q. It's alleged in paragraph 72 of the 21 complaint that you signed one or more of the 22 release forms discussed herein or the 23 precursors to them, including scholarship and 24 eligibility papers. 25 today cannot testify that you ever signed any But you as you sit here REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 186 1 document; is that right? 2 A. 3 documents. 4 sign them, I just -- 5 Q. I don't remember signing any I don't -- I didn't say I didn't But you cannot offer any evidence that 6 you signed any release forms or precursors to 7 them; is that right? 8 A. I have none of those forms. 9 Q. And you have no knowledge or 10 recollection of having signed any such forms, 11 correct? 12 A. Correct. 13 Q. So you may have or you may not have, 14 you just don't know? 15 A. I just don't know. 16 Q. And that same paragraph goes on to say 17 that the NCAA has interpreted as a release of 18 the student athletes' rights with respect to 19 his image, likeness and/or name. 20 any knowledge of the NCAA supposedly 21 interpreting documents as a release? 22 MR. CLOBES: 23 THE WITNESS: 24 25 Do you have Objection, form. No. BY MR. CURTNER: Q. When you read this complaint before it REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 233 1 be rebroadcast on ESPN Classic or something, 2 do you recall that topic, generally? 3 A. Yes, generally. 4 Q. And do you see there being benefits to 5 having now as you have children and 6 grandchildren for your children and 7 grandchildren to be able to see on ESPN 8 Classic or something like that one of your 9 games that you played when you were playing 10 for the University of Kentucky? 11 A. Yes. 12 Q. And are there -- similarly are there 13 downsides in your view with respect to 14 potential rebroadcasts of games that you were 15 involved in? 16 A. I can't think of a downside of a 17 rebroadcast of a game. 18 can't think of a downside. 19 Q. The downsides -- I Do you think that there might be 20 players on your team who would prefer that 21 that game not be rebroadcast? 22 MR. CLOBES: 23 THE WITNESS: 24 25 Objection to form. Yes. BY MR. SLAUGHTER: Q. And why? REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 248 1 C E R T I F I C A T E 2 3 4 G E O R G I A: 5 FULTON COUNTY: 6 7 8 9 I hereby certify that the foregoing deposition was reported, as 10 stated in the caption, and the questions 11 and answers thereto were reduced to the 12 written page under my direction; that the 13 foregoing pages represent a true and 14 correct transcript of the evidence 15 given. 16 any way financially interested in the 17 result of said case. I further certify that I am not in 18 Pursuant to Rules and Regulations 19 of the Board of Court Reporting of the 20 Judicial Council of Georgia, I make the 21 following disclosure: 22 I am a Georgia Certified Court 23 Reporter. I am here as an independent 24 contractor for Huseby, Inc. 25 REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400 In Re NCAA Student-Athlete Name, et al. Thad Jaracz 09-cv-1967-CW November 30, 2011 Page 249 1 I was contacted by the offices of 2 Huseby, Inc. to provide court 3 reporting services for this deposition. 4 I will not be taking this deposition under 5 any contract that is prohibited by O.C.G.A. 6 15-14-7 (a) or (b). 7 I have no written contract to 8 provide reporting services with any party 9 to the case, any counsel in the case, or 10 any reporter or reporting agency from whom 11 a referral might have been made to cover 12 this deposition. 13 and customary rates to all parties in the 14 case. 15 I will charge my usual This, the 4th day of December, 2011. 16 17 ______________________________ STEVE S. HUSEBY, CCR-B-1372 18 My Commission Expires January 20th, 2015. 19 20 21 22 23 24 25 REPORTED BY: Steven S. Huseby, RPR, CCR www.huseby.com HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400

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