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).

Download PDF
EXHIBIT M In Re NCAA Student-Athlete, et al. Patrick Maynor 09-cv-1967-CW November 14, 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 PATRICK MAYNOR NOVEMBER 14, 2011 12:00 P.M. KILPATRICK TOWNSEND & STOCKTON LLP 1100 PEACTHREE 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 6 1 behalf of antitrust plaintiffs from Zelle 12:06:36 2 Hofmann. 12:06:39 3 4 MR. ARAGON: ahead. 12:06:49 12:06:49 5 6 Leonard Aragon -- go MR. CAREY: Rob Carey, Hagens Berman, Plaintiffs. 12:06:49 12:06:49 7 MR. ARAGON: 8 Hagens Berman for plaintiffs, right of 12:06:55 9 publicity plaintiffs. 12:06:56 10 11 Leonard Aragon, MR. CURTNER: 12:06:54 Greg Curtner for the 12:06:58 NCAA. 12:06:59 12 PATRICK MAYNOR, 13 being first duly sworn, was examined and 14 testified as follows: 15 16 EXAMINATION BY MR. BRAUNIG: 17 Q. Good afternoon, Mr. Maynor. 12:07:14 18 A. How are you doing? 12:07:16 19 Q. Could you please state for the record 12:07:16 20 21 22 your full name and spell your last name. A. Patrick Fitzgerald Maynor, M-A-Y-N-O-R. 12:07:19 12:07:21 12:07:25 23 Q. What's your current address? 12:07:25 24 A. I live in Athens, Georgia. 12:07:27 25 Q. Do you know the address offhand? 12:07:28 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 14 1 2 Q. Do you have an expectation of making money from this lawsuit? 3 A. 4 Q. 12:13:44 money. 5 12:13:41 I do not have expectations of making 12:13:45 12:13:47 Have you been -- do you have an 12:13:47 6 understanding that as a class plaintiff you'll 12:13:50 7 receive any sort of bonus for being a 12:13:53 8 representative plaintiff? 12:13:56 9 MS. HOU: 10 Objection to form. THE WITNESS: 12:13:57 I'm not sure exactly 12:13:59 11 how that breakdown would work out. 12 sure. 12:14:03 13 BY MR. BRAUNIG: 12:14:03 14 Q. I'm not But as of right now, do you have an 12:14:00 12:14:04 15 expectation that you're going to receive a 12:14:05 16 bonus for being a class plaintiff? 12:14:07 17 MS. HOU: 12:14:10 18 THE WITNESS: Objection to form. I don't know. I 12:14:11 19 don't think so. 12:14:15 20 BY MR. BRAUNIG: 12:14:15 21 Q. How are you currently employed? 12:14:19 22 A. I'm in school. 12:14:20 23 Q. At Georgia's MBA program? 12:14:20 24 A. Correct. 12:14:24 25 Q. It's the Terry School of Business? 12:14:24 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 15 1 A. Correct. 12:14:25 2 Q. How long have you been in school at 12:14:26 3 Terry? 4 A. About a year and a half. 12:14:29 5 Q. So since probably September 2010? 12:14:32 6 A. That sounds about right. 12:14:36 7 Q. And do you have a plan for what you're 12:14:40 12:14:29 8 going to be doing after school when school 12:14:43 9 ends? 12:14:46 10 A. Moving to Manhattan in July. 12:14:46 11 Q. You are? 12:14:48 12 Who are you going to be working for? 12:14:50 13 A. Bank of America. 12:14:51 14 Q. Doing what? 12:14:52 15 A. Sales and trading. 12:14:52 16 Q. Equity trading or bonds or -- 12:14:54 17 A. Equity trading. 12:14:57 18 Q. Now, you graduated from Stanford in 12:14:58 19 2009; is that right? 12:15:02 20 A. Correct. 12:15:03 21 Q. And what did you do between the time 12:15:04 22 you graduated and when you started business 12:15:07 23 school? 12:15:09 24 25 A. I had a tryout for the Chicago Bears right after I graduated school. 12:15:10 12:15:14 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 20 1 2 3 A. Played fullback for about a year in high school as well. Q. 5 6 7 12:18:46 Were you -- 4 MS. HOU: 12:18:47 Objection to form. BY MR. BRAUNIG: Q. 12:18:43 12:18:47 12:18:48 Were you recruited as a fullback or just as a linebacker? 12:18:49 12:18:50 8 A. Just as a linebacker. 12:18:51 9 Q. What jersey number did you wear in 12:18:53 10 high school, if you remember? 11 A. 44. 12 Q. 44. 13 12:18:56 12:18:56 You were recruited to -- to various colleges; is that right? 12:18:57 12:19:07 14 A. Yes. 12:19:09 15 Q. Which college -- which colleges 12:19:10 16 recruited you? 12:19:11 17 MS. HOU: 18 THE WITNESS: Objection to form. Mostly I was 12:19:13 12:19:14 19 recruited by Stanford, Georgia Tech, Auburn, 12:19:16 20 Florida, Boston College, and Kansas State as 12:19:20 21 well. 12:19:28 22 eight. 12:19:29 23 BY MR. BRAUNIG: 12:19:30 24 25 Q. well? Those are -- those are the top five to And there were additional ones as 12:19:31 12:19:32 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 36 1 offensive side. 2 there -- was there anybody else who wore -- 12:31:35 3 other than your freshman year, was there 12:31:37 4 anybody else who wore 44 on the team? 12:31:39 When you were at Stanford was 5 MS. HOU: 6 THE WITNESS: Objection to form. 12:31:32 12:31:41 When I had -- when I 12:31:42 7 wore the number 44, I was the only one on the 12:31:44 8 team that wore that number. 12:31:46 9 BY MR. BRAUNIG: 12:31:47 10 Q. And as you said, there were people who 12:31:49 11 had the number 44 before you came to Stanford, 12:31:51 12 right? 12:31:55 13 A. Correct. 12:31:55 14 Q. And there have been people who have 12:31:55 15 had the number 44 since you left Stanford; is 12:31:57 16 that correct? 12:32:00 17 A. Correct. 12:32:00 18 Q. Do you know who wears the jersey 12:32:00 19 number 44 now? 12:32:04 20 A. I do. 12:32:05 21 Q. Who is it? 12:32:06 22 A. Chase Thomas. 12:32:06 23 Q. And what position does Chase Thomas 12:32:08 24 25 play? A. 12:32:10 Outside linebacker. 12:32:10 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 37 1 MR. HENN: 2 MR. BRAUNIG: 3 He's from Marietta. Is that right? BY MR. BRAUNIG: 4 Q. 5 linebacker? 6 A. 7 8 9 12:32:16 12:32:17 Same position that you played, outside 12:32:17 12:32:20 Yeah, they run a different defense now 12:32:20 but same -- right, same title. Q. 12:32:13 So to be clear, there is -- there is 12:32:23 12:32:25 currently at Stanford someone at -- wearing 12:32:29 10 the jersey number 44 and playing at 12:32:32 11 linebacker? 12:32:34 12 A. Yes. 12:32:35 13 Q. And is Chase Thomas to your knowledge, 12:32:41 14 the only person since you wore the jersey 44 12:32:43 15 at Stanford who's wearing that same jersey 12:32:43 16 number? 12:32:49 17 A. No, there was another -- another 12:32:49 18 linebacker before who also wore it before 12:32:49 19 Chase Thomas got it. 12:32:52 20 Q. Who was that? 12:32:54 21 A. Nick Macaluso. 12:32:54 22 Q. He's somebody you played with as well, 12:32:56 23 right? 12:32:58 24 A. Correct. 12:32:58 25 Q. So when you graduated he took your 12:32:59 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 50 1 Q. Did you ever -- ever accept money from 12:42:46 2 anyone while you were a student athlete, from 12:42:50 3 anyone other than -- than your parents or from 12:42:53 4 Stanford? 12:42:56 5 A. 12:42:56 No. 6 7 MS. HOU: Objection to form. BY MR. BRAUNIG: 12:42:57 12:42:58 8 Q. 9 Stanford? 12:43:01 10 A. I did. 12:43:02 11 Q. In addition to the full scholarship, 12:43:03 Did you have a full scholarship at 12:42:59 12 you received other benefits from Stanford, 12:43:07 13 right? 12:43:10 14 right, received benefits of coaching? You were -- subject of coaching, 15 MS. HOU: 16 THE WITNESS: Objection to form. We had coaches on 12:43:13 12:43:16 12:43:17 17 the team, I mean, is that what you're saying? 12:43:18 18 BY MR. BRAUNIG: 12:43:20 19 Q. Yeah. 20 A. Yes, yes. 12:43:21 21 Q. And they helped you grow and develop 12:43:22 22 Yeah, and they were -- as a player? 12:43:21 12:43:23 23 A. Yes. 12:43:24 24 Q. You also had a strength trainer, 12:43:24 25 someone who helped you with your training? 12:43:27 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 51 1 A. Yes. 12:43:28 2 Q. And did you have any academic 12:43:29 3 tutoring? 12:43:31 4 A. We did. 12:43:32 5 Q. And that was something that the school 12:43:33 6 provided? 12:43:34 7 MS. HOU: 8 THE WITNESS: 9 10 11 12 13 14 15 Objection to form. Yes. BY MR. BRAUNIG: Q. 12:43:37 12:43:41 For the first three years I lived in a 12:43:42 dorm. Q. 12:43:37 And when you lived at college, did you 12:43:39 live in a dorm? A. 12:43:35 12:43:46 And the second two years, did you live 12:43:46 with friends off campus? 12:43:48 16 A. Yes. 12:43:49 17 Q. And were those, did the people you 12:43:49 18 lived with, were they other -- other players? 12:43:52 19 A. Mostly basketball players. 12:43:55 20 Q. In your -- in your dorm room or 12:43:57 21 apartment, did you guys have -- have a TV? 12:44:00 22 A. In our apartment, we did, yes. 12:44:02 23 Q. What about in your dorm room? 12:44:07 24 A. Dorm room I did not. 12:44:09 25 Q. Was there like a communal TV in a TV 12:44:11 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 190 1 same principle as the video game, pretty 03:45:06 2 equitable distribution. 03:45:08 3 BY MR. HENN: 03:45:09 4 Q. And in the event that a player is not 03:45:09 5 depicted in the broadcast, it's your position 03:45:12 6 that they should still get compensated because 03:45:15 7 of the contribution they made to the team; is 03:45:19 8 that correct? 03:45:23 9 A. Correct. 03:45:23 10 Q. That's your position? 03:45:24 11 A. Correct. 03:45:25 12 13 14 MR. BOARDMAN: Object to form. BY MR. HENN: Q. 03:45:25 03:45:29 Does that include people on the 03:45:29 15 practice squad who don't even suit up for the 03:45:31 16 games? 03:45:34 17 A. 18 19 Well, there's no -- there's no direct practice squad in college football but -Q. Let's say like the redshirt guys who 03:45:34 03:45:37 03:45:40 20 are technically not playing their freshman 03:45:45 21 year but they are practicing with the team. 03:45:48 22 A. Yeah, because they are adding value 03:45:49 23 throughout the whole year in practice and 03:45:51 24 whatnot. 03:45:53 25 Q. Okay. And why should they get 03:45:53 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 217 1 pay or benefits for playing a sport; is that 04:24:04 2 right. 04:24:13 3 MS. HOU: 4 THE WITNESS: 5 6 Same objection. That's correct. BY MR. CURTNER: Q. 04:24:13 04:24:14 04:24:15 And you certified every year that you 04:24:16 7 were an amateur in compliance with those 04:24:18 8 rules, correct? 04:24:20 9 A. We had to sign forms every year, so 04:24:22 10 yeah, I think that's -- I believe that's what 04:24:25 11 you're talking about, the eligibility forms we 04:24:30 12 had to sign every year. 04:24:32 13 Q. Did you ever object to participating 04:24:34 14 in collegiate sports as an amateur? 04:24:37 15 MS. HOU: 04:24:40 16 THE WITNESS: Objection to form. Could you rephrase 04:24:47 17 04:24:48 18 611b that, please? BY MR. CURTNER: 04:24:50 19 20 Q. Did you ever object to participating in college sports as an amateur? 21 MS. HOU: 22 THE WITNESS: Same objection. 04:24:50 04:24:52 04:24:54 Well, we were forced 04:25:00 23 to sign those documents every year so we -- 04:25:04 24 you know, we didn't openly object to the 04:25:07 25 coaching staff who was making us sign those 04:25:12 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 218 611b 1 papers. 2 BY MR. CURTNER: 3 Q. No, we didn't object. 04:25:15 04:25:17 Well, who made you sign these papers, 04:25:17 4 sir? They were giving you a scholarship and 04:25:19 5 you wanted to play football under the rules. 04:25:23 6 Did somebody twist your arm or how were you 04:25:25 7 forced? 04:25:28 8 MS. HOU: 9 THE WITNESS: Objection to form. 04:25:29 Well, they bring you 04:25:30 10 in a little tiny room, they give you a stack 04:25:32 11 of papers to sign, they go through it really 04:25:34 12 quickly, and if you don't sign them, you 04:25:36 13 don't -- you know, you don't get to practice, 04:25:39 14 you don't have eligibility. 04:25:41 15 BY MR. CURTNER: 04:25:44 16 Q. Right, but you understood the basic 04:25:44 17 rule was that you had to be an amateur in 04:25:46 18 order to play the sport, you knew that all 04:25:52 19 along, isn't that right? 04:25:54 20 MS. HOU: 21 THE WITNESS: 22 23 24 25 Objection to form. I knew that, yes. BY MR. CURTNER: Q. 04:25:57 04:26:00 You knew that when you were in high school that that's the way it worked? MS. HOU: 04:25:55 Objection to form. 04:26:00 04:26:02 04:26:04 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 272 1 THE WITNESS: I'm -- I'm not sure 05:27:02 2 if it did or not. 05:27:03 3 BY MR. CURTNER: 05:27:06 4 Q. Did anybody ever offer you any money 05:27:06 5 for your name, image or likeness before you 05:27:08 6 started playing football at Stanford? 05:27:12 7 A. Not that I can remember, no. 8 Q. Would you agree that your playing time 05:27:18 9 10 at Stanford made you a lot better known than 05:27:21 you were before? 05:27:25 11 MS. HOU: 12 THE WITNESS: 13 14 05:27:14 Objection to form. True, yes, true. BY MR. CURTNER: Q. 05:27:25 05:27:27 05:27:31 Would you also agree that you got a 05:27:31 15 very good education out of your scholarship at 05:27:32 16 Stanford? 05:27:35 17 A. Yes. 05:27:37 18 Q. And would you agree that Stanford made 05:27:40 19 a pretty good deal and that you got the 05:27:45 20 benefit of that deal -- 05:27:47 21 22 23 MS. HOU: Objection to form. BY MR. CURTNER: Q. -- by going there and getting a 05:27:48 05:27:51 05:27:51 24 scholarship to play football and getting a 05:27:53 25 terrific education? 05:27:55 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 273 1 MR. BOARDMAN: 2 THE WITNESS: Objection to form. 05:27:56 I don't know if they 05:27:57 3 got any less benefit than I did out of it or 05:27:58 4 more -- or more or less, so I don't really 05:28:00 5 know. 05:28:02 6 BY MR. CURTNER: 7 Q. I can't say that for certain. 05:28:04 Well, we won't know your benefit until 05:28:04 8 we see how you do at -- as an investment 05:28:06 9 banker at Bank of America, will we? 05:28:09 10 A. Exactly. 11 Q. You may turn out to be the richest man 05:28:14 12 05:28:13 on North America in ten years. 05:28:16 13 A. I hope so. 05:28:18 14 Q. Right? 05:28:19 15 You understand, sir, when ESPN Classic -- Well, I hope so too. 05:28:34 16 and I think you said you thought it was ESPN 05:28:40 17 Classic but you weren't sure -- shows a 05:28:43 18 rebroadcast of a Stanford/USC game or a 05:28:44 19 Stanford/UW game, that that is ESPN and the 05:28:47 20 Pac 10 who are selling those rights and not 05:28:53 21 the NCAA, correct? 05:28:56 22 MS. HOU: 23 THE WITNESS: Objection to form. Could you repeat 05:28:58 05:29:00 24 that one more time, please? 05:29:07 25 BY MR. CURTNER: 05:29:11 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 279 1 screen now. 05:34:45 2 (The record was read.) 3 THE WITNESS: 4 question. 5 That's a pretty long 05:35:30 BY MR. CURTNER: 6 Q. 05:34:46 Could you break that down, please. 05:35:31 05:35:33 You're free to go out and sell your 05:35:34 7 appearance, your name, image, whatever it is 05:35:36 8 you own after you get out of school, right, 05:35:40 9 for whatever you can get for it? 05:35:42 10 MS. HOU: 11 THE WITNESS: Sure. 05:35:45 12 MR. CURTNER: I have no further 05:35:48 13 Objection to form. questions, thank you. 05:35:44 05:35:49 14 MR. HENN: 15 EXAMINATION I have a follow-up. 05:35:51 05:35:51 16 BY MR. HENN 05:35:51 17 Q. 05:35:53 Mr. Maynor, I'm sorry to have to do 18 this, but I looked back and realized that I 05:35:55 19 misspoke when I was asking you a question and 05:35:57 20 I didn't get the right one. 05:35:59 21 At one point I asked you about your 05:36:01 22 testimony about a conspiracy or belief that 05:36:02 23 CLC and the NCAA conspires together in some 05:36:08 24 way. 05:36:12 25 Do you remember that? A. I do. 05:36:13 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 284 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, et al. Patrick Maynor 09-cv-1967-CW November 14, 2011 Page 285 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 16th day of November, 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

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?