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).

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

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 [phone]

In Re NCAA Student-Athlete Name, et al.
Thad Jaracz

09-cv-1967-CW
November 30, 2011
Page 186

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document; is that right?

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A.

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documents.

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sign them, I just --

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Q.

I don't remember signing any
I don't -- I didn't say I didn't

But you cannot offer any evidence that

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you signed any release forms or precursors to

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them; is that right?

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A.

I have none of those forms.

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Q.

And you have no knowledge or

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recollection of having signed any such forms,

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correct?

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A.

Correct.

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Q.

So you may have or you may not have,

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you just don't know?

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A.

I just don't know.

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Q.

And that same paragraph goes on to say

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that the NCAA has interpreted as a release of

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the student athletes' rights with respect to

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his image, likeness and/or name.

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any knowledge of the NCAA supposedly

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interpreting documents as a release?

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MR. CLOBES:

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THE WITNESS:

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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 [phone]

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,

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do you recall that topic, generally?

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A.

Yes, generally.

4

Q.

And do you see there being benefits to

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having now as you have children and

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grandchildren for your children and

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grandchildren to be able to see on ESPN

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Classic or something like that one of your

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games that you played when you were playing

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for the University of Kentucky?

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A.

Yes.

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Q.

And are there -- similarly are there

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downsides in your view with respect to

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potential rebroadcasts of games that you were

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involved in?

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A.

I can't think of a downside of a

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rebroadcast of a game.

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can't think of a downside.

19

Q.

The downsides -- I

Do you think that there might be

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players on your team who would prefer that

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that game not be rebroadcast?

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MR. CLOBES:

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THE WITNESS:

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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 [phone]

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

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G E O R G I A:

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FULTON COUNTY:

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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

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written page under my direction; that the

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foregoing pages represent a true and

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correct transcript of the evidence

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given.

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any way financially interested in the

17

result of said case.

I further certify that I am not in

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Pursuant to Rules and Regulations

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of the Board of Court Reporting of the

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Judicial Council of Georgia, I make the

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following disclosure:

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I am a Georgia Certified Court

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Reporter.

I am here as an independent

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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 [phone]

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.

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I will not be taking this deposition under

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any contract that is prohibited by O.C.G.A.

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15-14-7 (a) or (b).

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I have no written contract to

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provide reporting services with any party

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to the case, any counsel in the case, or

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any reporter or reporting agency from whom

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a referral might have been made to cover

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this deposition.

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and customary rates to all parties in the

14

case.

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I will charge my usual

This, the 4th day of December, 2011.

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______________________________
STEVE S. HUSEBY, CCR-B-1372

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My Commission Expires
January 20th, 2015.

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REPORTED BY: Steven S. Huseby, RPR, CCR
www.huseby.com
HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 [phone]