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 S

In Re NCAA Student-Athlete, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
1
1

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

2

OAKLAND DIVISION

3
4

in re NCAA Student-Athlete Name and
5

Likeness Licensing Litigation

Case No.
09-cv-1967-CW

6
7
8

* MAY CONTAIN CONFIDENTIAL INFORMATION *

9

- - -

10
11

VIDEOTAPED DEPOSITION OF
ERIC RILEY

12

NOVEMBER 11, 2011
9:00 A.M.

13
14
15

KILPATRICK TOWNSEND & STOCKTON LLP
1100 PEACTHREE STREET, SUITE 2800

16

ATLANTA, GEORGIA

17
18
19
20

REPORTED BY:
STEVEN S. HUSEBY, RPR

21
22
23
24
25

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
6
1

of publicity plaintiffs.

2
3

MR. KING:

09:09:50
John King, Hausfeld,

LLP, for the antitrust plaintiffs.

4

MR. BOARDMAN:

Thomas Boardman,

09:09:52
09:09:53
09:09:56

5

Pearson, Simon, Warshaw & Penny, for the

09:09:57

6

antitrust plaintiffs.

09:10:00

7

ERIC RILEY,

8

being first duly sworn, was examined and

9

testified as follows:

10
11
12
13

EXAMINATION
BY MR. WIERENGA:
Q.

Good morning, sir.

Could you please

state your full name for the record.

09:10:17
09:10:18

14

A.

Eric Riley.

09:10:21

15

Q.

Okay.

09:10:22

16

A.

Oh, yes.

17

Q.

Have you ever been deposed before,

18

Mr. Riley?

09:10:29

19

A.

09:10:30

20
21
22

Do you have a middle name?
Eric Kendall Riley.

Yes, but it wasn't this many lawyers.

It was just one.
Q.

On how many occasions have you been

deposed?

09:10:24
09:10:27

09:10:34
09:10:37
09:10:40

23

A.

Once.

09:10:41

24

Q.

And how long ago was that?

09:10:41

25

A.

About four years ago.

09:10:43

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
18
1

A.

One year.

09:20:34

2

Q.

And before we get too far, with

09:20:37

3

Boston, Dallas and Minnesota, the three NBA

09:20:40

4

teams you told me about, did you sign

09:20:42

5

year-long contracts?

09:20:44

6

A.

Yes.

09:20:45

7

Q.

Were you on those teams for a full

09:20:45

8

season?

09:20:48

9

A.

Yes.

10

Q.

Okay.

11

09:20:49
Before Minnesota, who did you

play for?

09:20:50
09:20:54

12

A.

Clippers.

09:20:55

13

Q.

Los Angeles?

09:20:58

14

A.

Yes.

09:20:59

15

Q.

And how long did you play for the

09:21:01

16

Clippers?

09:21:02

17

A.

One year, or half a year.

09:21:04

18

Q.

What kind of a contract did you have

09:21:07

19

with the Clippers?

20

expert here --

Well, I -- and I'm no

09:21:09
09:21:09

21

A.

You mean how much or what --

09:21:14

22

Q.

No, was it like 30 days or six months

09:21:15

23
24
25

or one year, do you know the term?
A.

Well, it was minimum guaranteed for

that one year.

So it was minimum.

09:21:18
09:21:20
09:21:22

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
20
1
2
3
4

Michigan?
A.

09:22:13
No, Dallas drafted me and they traded

me on draft day to Houston.
Q.

So Dallas drafted you but in that

09:22:13
09:22:16
09:22:20

5

first -- Dallas drafted you right out of

09:22:24

6

Michigan, but they traded you immediately so

09:22:27

7

you never played for Dallas that -- in your

09:22:30

8

first two years, right?

09:22:33

9

A.

Yep, yes.

09:22:34

10

Q.

And then while you were at Michigan

09:22:46

11

you lived in Ann Arbor, correct?

09:22:49

12

A.

Yes.

09:22:52

13

Q.

And you were there from '88 through

09:22:53

14

'93; is that right?

09:22:56

15

A.

Yes.

09:22:58

16

Q.

Did you live in West Quad?

09:22:59

17

A.

I think I did one year, yes.

09:23:02

18

Q.

Me too.

09:23:05

19

A.

Oh, you --

09:23:06

20

Q.

In fact, I think we were there the

09:23:07

21

same year.

22

A.

23
24
25

I was there in '88 too.

Okay.

Yeah.

I say one year, my

freshman year.
Q.

And before going to Michigan, you

lived in Cleveland; is that right?

09:23:09
09:23:11
09:23:13
09:23:15
09:23:18

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
21
1

A.

Yes.

09:23:19

2

Q.

And you were born and raised in

09:23:20

3

Cleveland?

09:23:22

4

A.

Yes.

09:23:22

5

Q.

Outside of the six months that you

09:23:27

6

played for the Clippers, have you ever lived

09:23:30

7

in California?

09:23:32

8

A.

No.

09:23:33

9

Q.

Have you ever had a California

09:23:39

10

driver's license?

09:23:41

11

A.

Yes.

09:23:42

12

Q.

When did you have a California

09:23:43

13

driver's license?

09:23:45

14

A.

During that time, I think, I got one.

09:23:47

15

Q.

Do you have a California driver's

09:23:50

16

license today?

09:23:53

17

A.

No.

09:23:53

18

Q.

Do you have an Ohio driver's license

09:23:54

19

today?

20

A.

No, Texas.

09:23:56

21

Q.

Texas.

09:23:56

22
23
24
25

09:23:55

How long have you had a Texas

driver's license?
A.

Since -- I don't know, I don't

remember exactly.
Q.

Several years?

09:24:00
09:24:01
09:24:06
09:24:07

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
33
1
2

Q.

you primarily?

3
4

A.

Q.

I forgot his name right now.

I can't

A.

09:36:25
09:36:31

And so why did you choose Michigan

over the other schools in your final list?

7

09:36:21
09:36:24

think of his name right now.

5
6

So who was responsible for recruiting

Just mainly because I liked the

09:36:33
09:36:35
09:36:38

8

academics and then I felt comfortable around

09:36:41

9

the staff, so, yeah.

09:36:46

10

Q.

Were the academics of these schools

09:36:49

11

important to you in deciding which one to go

09:36:52

12

to?

09:36:54

13

A.

Yes.

09:36:54

14

Q.

Was getting a degree important to you

09:36:55

15

while you were in school?

09:36:57

16

A.

Yes.

17

Q.

You got a degree from Michigan, right? 09:36:58

18

A.

Yes.

09:37:00

19

Q.

And you got that in the five years

09:37:01

20

09:36:58

that you were there?

09:37:03

21

A.

Yes.

09:37:04

22

Q.

Tell me what you can remember about

09:37:17

23

what the Michigan coaches said about why you

09:37:20

24

should come play for Michigan?

09:37:23

25

MR. BOARDMAN:

Objection, form.

09:37:24

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
35
1

school?

09:38:44

2

A.

No.

3

Q.

Yes.

09:38:49

4

A.

No, to this day I don't know how much

09:38:49

5
6

You mean a dollar amount?

everything cost.
Q.

09:38:45

09:38:51

Did they ever say things like if you

09:38:52

7

come here you won't have to worry about

09:38:53

8

tuition or room and board, we'll take care of

09:38:55

9

all that, anything like that?

09:38:59

10

I think that was -- that was -- I

09:39:00

11

think I understood that, I didn't think my

09:39:04

12

parents would have to pay anything.

09:39:07

13

A.

Q.

If -- and this didn't happen but let

09:39:08

14

me ask you a hypothetical.

15

coaches had said we'd love to have you come,

09:39:14

16

there's a place for you on our team but we can

09:39:17

17

only offer you a half scholarship, do you

09:39:20

18

think you still would have gone to Michigan?

09:39:24

19

A.

If the Michigan

If the other schools were just

09:39:12

09:39:26

20

offering half scholarships also maybe, but if

09:39:29

21

they were offering full scholarship and they

09:39:32

22

offered half, I probably would go somewhere

09:39:36

23

else.

09:39:38

24
25

Q.

While you were at Michigan, did you

ever have any issues with NCAA eligibility?

09:39:39
09:39:43

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
55
1
2
3

A.

Because I felt that exposure and just

more chance to be seen.
Q.

09:58:00
09:58:06

Was that important to you while you -- 09:58:12

4

while you were at Michigan, the exposure and

09:58:14

5

the chance to be seen?

09:58:17

6
7

A.

Yes, yes, once we won it and I saw the 09:58:18

difference, yes.

09:58:21

8

Q.

What was the difference that you saw?

09:58:22

9

A.

Media attention as far as our games,

09:58:27

10

they were pretty much all picked up by ABC,

09:58:29

11

and were pretty much all picked up.

09:58:34

12

Q.

13

at school?

14

A.

And did you like that while you were

I wouldn't say I liked it.

09:58:37
09:58:38

I just

09:58:39

15

felt it was more of an opportunity to make it

09:58:43

16

to the NBA if I get more exposure, so yes.

09:58:46

17

Q.

So you felt the more that your games

09:58:50

18

were televised the greater the chance that you

09:58:51

19

would come to the attention of the NBA scouts.

09:58:54

20

Is that fair to say?

09:58:56

21

A.

Yes.

09:58:58

22

Q.

You didn't object to your games being

09:58:58

23

televised while you were in school, right?

09:59:00

24

A.

No.

09:59:02

25

Q.

At the time did you think that

09:59:02

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
57
1

Q.

2

right?

3

A.

Exactly.

10:00:22

4

Q.

During your fourth year or the first

10:00:22

Because the team wasn't as good,

10:00:20
10:00:21

5

of the Fab Five years, do you remember how

10:00:26

6

many of your regular season games were on TV?

10:00:28

7

A.

I think all of them.

10:00:31

8

Q.

Is that true for your last year as

10:00:33

9

well?

10:00:38

10

A.

Yes.

10:00:38

11

Q.

And while you were playing all these

10:00:43

12

games, you knew at the time that they were --

10:00:47

13

that there were television cameras in the

10:00:50

14

auditorium or the stadium, right?

10:00:53

15

A.

Yes.

16

Q.

You took the court knowing that people 10:00:55

17

were recording what you were doing, right?

10:00:55

10:00:57

18

A.

Yes.

10:00:58

19

Q.

While you were playing at Michigan,

10:01:06

20

were you ever -- did you give press interviews

10:01:07

21

or participate in press conferences?

10:01:08

22

A.

Yes.

10:01:12

23

Q.

About how often?

10:01:13

24

A.

Probably before a game and after a

10:01:14

25

game.

10:01:16
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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
58
1

Q.

Every game?

10:01:16

2

A.

Yes.

10:01:17

3

Q.

Was that something that you were

10:01:23

4

required to do or that you chose to do?

10:01:25

5

A.

Required to do it.

10:01:27

6

Q.

The school asked you to make yourself

10:01:28

7

available to the press?

10:01:31

8

A.

Yes.

10:01:32

9

Q.

Did you ever have any objection to

10:01:33

10

making yourself available to the press?

10:01:34

11

A.

Sometimes, yes.

10:01:37

12

Q.

If you were -- didn't feel like

10:01:39

13
14

talking in that particular situation?
A.

Yeah, and just getting burned with

10:01:41
10:01:42

15

stories that they twist your words, so I just

10:01:44

16

felt like I didn't want to talk after a while.

10:01:48

17

Q.

Were there any particular instances

10:01:50

18

you have in mind where you felt like the press

10:01:52

19

misrepresented what you had said?

10:01:54

20

A.

Not really.

I don't really remember

10:01:57

21

now, but I just remember being a little bitter

10:02:00

22

from not -- you know, not wanting to talk to

10:02:03

23

certain reporters, certain ones that I knew

10:02:07

24

would twist your words.

10:02:09

25

Q.

Do you know if your picture, either

10:02:12

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
59
1

any kind of a portrait or like just a picture

10:02:15

2

of a game that you appeared in, did it ever

10:02:18

3

appear in the press while you were at

10:02:21

4

Michigan?

10:02:23

5

A.

Yes.

10:02:23

6

Q.

Was that something that happened

10:02:24

7

regularly?

10:02:25

8

A.

Yes.

10:02:25

9

Q.

Did you have any objection to that?

10:02:26

10

A.

No.

10:02:27

11

Q.

Were you ever paid for that?

10:02:28

12

A.

No.

10:02:34

13

Q.

Did you ever ask anyone to pay you for 10:02:36

14

that?

10:02:42

15

A.

During that time?

10:02:42

16

Q.

Uh-huh.

10:02:43

17

A.

No.

10:02:45

18

Q.

While you were at Michigan, did the

10:02:45

19

athletic department have someone take like a

10:02:50

20

team photo and then maybe an individual photo

10:02:53

21

of you in your uniform?

10:02:56

22

A.

Yes.

10:02:57

23

Q.

Did that get printed in game manuals

10:02:58

24

and other kind of university materials like

10:03:00

25

that?

10:03:02
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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
60
1

A.

Yes.

10:03:02

2

Q.

Did you sign any paperwork associated

10:03:03

3

with that that you can recall?

10:03:06

4

A.

I don't remember.

10:03:07

5

Q.

Did you have a problem with the

10:03:07

6
7

university doing that?
A.

No.

10:03:10

8
9

10:03:10

MR. KING:
fairly soon?

Could we take a break

10

It's been about an hour.
MR. WIERENGA:

Sure.

10:03:14
10:03:17

And I should 10:03:19

11

have said, if you need a break, please let me

10:03:20

12

know because you're the most important person

10:03:22

13

in the room.

10:03:24

14

BY MR. WIERENGA:

10:03:29

15

Q.

And do you know the game programs that 10:03:29

16

your picture appeared in, Michigan would sell

10:03:32

17

those to people in the stadium, right?

10:03:34

18

A.

Yes.

10:03:38

19

Q.

Did you have a problem with Michigan

10:03:40

20

selling this magazine that had your picture in

10:03:41

21

it without paying you?

10:03:44

22

A.

At the time, no.

10:03:45

23

Q.

Do you now?

10:03:46

24

A.

They are still selling them, yes.

10:03:48

25

Q.

Do you have a problem today with what

10:03:52

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
65
1

A.

Just during the season.

10:22:44

2

Q.

Did you live at the -- you lived in

10:22:46

3

the dorms at Michigan for awhile, right, but

10:22:50

4

not your whole time there?

10:22:53

5

A.

Just one year, just freshman year.

10:22:54

6

Q.

Where did you live after freshman

10:22:56

7

year?

10:22:58

8

A.

9

Ann Arbor.

10:23:03

Q.

10:23:04

10
11

Just different apartments that were in 10:22:58

And did the school pick up your rent

at those apartments?

10:23:06

12

A.

No.

13

Q.

They paid you --

10:23:09

14

A.

-- an allowance to get an apartment,

10:23:11

15
16
17

I mean, they paid me --

yes.

10:23:07

10:23:12
Q.

Did you receive any tutoring or

academic support while you were at Michigan?

10:23:17
10:23:21

18

A.

Yes.

10:23:23

19

Q.

How did that work?

10:23:24

20

A.

If I needed a tutor, I would ask the

10:23:27

21

10:23:31

22

would set it up and that tutor would call me

10:23:35

23

and we would meet up.

10:23:38

24

611b

counselor, I need a tutor for this, and they

pay for it.

25

Q.

And I didn't have to

What was your major?

10:23:41
10:23:43

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
66

611b

1

A.

General studies.

10:23:48

2

Q.

After you had -- you had played your

10:23:49

3

final season at Michigan, you exhausted your

10:23:58

4

eligibility, were you still on campus for a

10:24:02

5

few months after you finished up your studies?

10:24:04

6

A.

No.

10:24:07

7

Q.

You left immediately?

10:24:07

8

A.

Yes.

10:24:08

9

Q.

Had you already earned enough credits

10:24:08

10

to graduate?

10:24:10

11

611b

A.

Yes.

10:24:11

12

Q.

Did you take any -- were you taking

10:24:13

13

any classes during your last semester at

10:24:15

14

Michigan?

10:24:19

15

A.

No.

10:24:19

16

Q.

Did -- before you were drafted by the

10:24:21

17

NBA did you participate if any pro days or

10:24:25

18

tryouts or anything like that for NBA teams?

10:24:28

19

A.

Yes.

10:24:31

20

Q.

Did the Michigan athletic department

10:24:34

21

staff, either the coaches or the trainers or

10:24:36

22

anyone like that help you prepare for your pro

10:24:38

23

tryouts or your pro days or whatever you might

10:24:41

24

have done for the NBA?

10:24:46

25

A.

No.

10:24:47

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
67
1

Q.

Did you ask them to?

10:24:48

2

A.

No.

10:24:48

3

Q.

When did you -- when did you decide to 10:24:49

4
5
6

declare for the NBA draft?
A.

When you're a senior, I don't think

it's -- you don't have an option, really.

10:24:54
10:24:57
10:25:00

7

Q.

Well, you could have --

8

A.

I could have opted out of it, I guess. 10:25:06

9

Q.

Did you ever consider, you know, maybe 10:25:07

10:25:03

10

going into the NBA draft before you had

10:25:10

11

completed your eligibility to play at

10:25:12

12

Michigan?

10:25:14

13

A.

No.

10:25:14

14

Q.

Why not?

10:25:15

15

A.

Just because of the situation, I

10:25:15

16

didn't -- I was coming off the bench my junior

10:25:18

17

year, so I felt what's the point.

10:25:23

18
19
20
21
22

Q.

You were concerned you wouldn't be

10:25:25

drafted or wouldn't be drafted very highly?

10:25:27

A.

Exactly, so I just finished up my

degree.
Q.

10:25:29
10:25:32

And it was more important for to you

10:25:32

23

finish up and get your degree than maybe be

10:25:35

24

drafted?

10:25:39

25

A.

Yes.

10:25:39

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
77
1

your picture?

10:34:26

2

A.

No.

10:34:27

3

Q.

You don't know if you signed that

10:34:28

4

piece of paper or not?

10:34:29

5

A.

I don't know.

10:34:30

6

Q.

Has anyone at Michigan talked to you

10:34:31

7

since graduation and said hey, you can't do

10:34:35

8

something because you signed away your rights

10:34:39

9

to the University of Michigan?

10:34:41

10

A.

No.

10:34:43

11

Q.

And no one from the NCAA has

10:34:44

12

approached you at any point and said hey, you

10:34:50

13

can't do something because you signed away

10:34:52

14

your rights to the NCAA, correct?

10:34:54

15

A.

That's correct.

I guess if I was

10:34:56

16

selling the games, if I was trying to sell

10:35:01

17

them to a local station they would probably

10:35:03

18

stop it.

10:35:05

19

Q.

What makes you say that?

10:35:05

20

A.

I mean, because I don't think they

10:35:07

21

would give me the authorization to sell the

10:35:09

22

games.

10:35:12

23

Q.

Have you ever approached Michigan?

24

Let's start with Michigan first.

25

ever approached Michigan and asked for

Have you

10:35:13
10:35:16
10:35:18

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
78
1

permission to sell some footage that they

10:35:21

2

owned of you playing basketball?

10:35:25

3

A.

No.

10:35:26

4

Q.

Have you ever approached the big ten

10:35:27

5

conference about potentially using some

10:35:28

6

footage that they have of you playing

10:35:30

7

basketball?

10:35:32

8

A.

No.

10:35:33

9

Q.

Have you ever approached the NCAA

10:35:34

10

about using some footage that they may have of

10:35:37

11

you playing basketball?

10:35:40

12

A.

No.

13

Q.

Has anyone from -- you understand that 10:35:44

10:35:44

14

CLC, who I'm pointing at Mr. Boyle because

10:35:46

15

he's their lawyer, that they are a defendant

10:35:49

16

in this lawsuit as well?

10:35:51

17

A.

Yes, I understand, yeah.

10:35:52

18

Q.

Has anyone from CLC ever come to you

10:35:55

19

and said hey, Mr. Riley, you can't do

10:35:58

20

something because you signed away your rights

10:36:00

21

to Michigan or the NCAA or CLC or anyone like

10:36:02

22

that?

10:36:05

23

A.

No.

10:36:05

24

Q.

Have you -- well, so we've talked

10:36:06

25

about Mr. Calip, Mr. Mills, Mr. King are three

10:36:26

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
124
1

have a certain player, and maybe not give them

11:19:09

2

the money while he's in college but once he

11:19:13

3

graduates he can get the money out of his

11:19:16

4

trust, then yes.

11:19:19

5

Q.

Why do you think Nike shouldn't be

11:19:20

6

allowed to give them the money while they are

11:19:21

7

in college?

11:19:23

8
9

A.

Just because of the -- they are in

11:19:24
11:19:29

10

distract from them wanting to stay in school

11:19:31

11

611b

school, you know, like that would probably

and do their work.

11:19:34

12

You think it's important in general

11:19:36

13

that college athletes approach what they are

11:19:37

14

doing as being both students and athletes?

11:19:40

15

Q.

A.

Yeah, I feel a certain amount of money 11:19:43

16

up to a certain point might distract from

11:19:47

17

that, but I mean, I think four or five

11:19:50

18

thousand, ten thousand a year wouldn't

11:19:53

19

district that.

But if you got two or three

11:19:55

20

hundred thousand a year that might distract

11:19:58

21

them from wanting to stay in school.

11:20:00

22

that's just my personal opinion.

23
24
25

MR. WIERENGA:

And

11:20:03

Let's take a break

he needs to change the tape.
THE VIDEOGRAPHER:

11:20:04
11:20:06

This is the end 11:20:08

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
139
1

came out, they just had different versions of

11:50:17

2

it.

11:50:20

3
4
5

Q.

Do you think this is Upper Deck, this

card?
A.

11:50:22
11:50:24

No, I have no clue, I thought -- I

11:50:24

6

just assumed that, I never researched it, each

11:50:26

7

different card.

11:50:29

8
9
10

Q.

Do you know when this -- when this

11:50:30

card hit the market -- you know, was

11:50:32

introduced?

11:50:33

11

A.

It says 1993 on the card.

11:50:35

12

Q.

Does it?

11:50:38

13

A.

Yeah.

11:50:39

14

Q.

Oh, yeah, you're right, it does.

11:50:40

15
16
17

Okay.
A.

11:50:42
On the second one right here, I don't

know what it is.

11:50:42
11:50:44

18

Q.

Oh, yes, you're right.

11:50:45

19

A.

I don't know.

11:50:48

20

Q.

Okay.

21

So do you think this is another 11:50:48

rookie card?

11:50:51

22

A.

I guess, yeah.

11:50:54

23

Q.

On the second page, is that your

11:50:57

24

autograph?

11:51:02

25

A.

11:51:02

Yes, it is.

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
140
1

Q.

2

cards?

3

A.

Yes, yes.

11:51:08

4

Q.

Tell me what you recall about being

11:51:11

5
6

Have you ever been paid to autograph

11:51:07

paid to autograph cards.
A.

11:51:04

11:51:12

It was more of a convention, I've been 11:51:15

7

in maybe two conventions and I would sit at a

11:51:19

8

table and sign whatever is in front of me.

11:51:22

9
10
11

Q.

And when -- when did you attend those

conventions?
A.

I did one in L.A. when I was playing

11:51:26
11:51:29
11:51:30

12

for the Clippers, and I did another one in the

11:51:32

13

summertime in Houston and I think it was after

11:51:36

14

I played with the Rockets --

11:51:41

15
16

Q.

Were you paid -- I'm sorry, were you

paid to attend those conventions?

11:51:47
11:51:49

17

A.

Yes.

11:51:50

18

Q.

By the convention organizer?

11:51:52

19

A.

Yes, by the person who set it up, yes. 11:51:55

20

Q.

Do you remember how much you were

21
22
23
24
25

paid?
A.

11:51:58
I think it was about 2,000, around

2,000 for each one, yeah.
Q.

11:51:57

And at those conventions, would you

sometimes be asked to sign Michigan

11:51:58
11:52:03
11:52:04
11:52:06

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
141
1

memorabilia?

11:52:09

2

A.

Yes.

11:52:09

3

Q.

Did that happen often?

11:52:10

4

A.

Yes.

11:52:11

5

Q.

Did it happen more often than you

11:52:13

6

would be asked to sign Clipper memorabilia or

11:52:14

7

Rockets memorabilia?

11:52:17

8
9

A.

Yes, yes.

Well, maybe in Houston, it

11:52:19

was more the Rockets because we did win a

11:52:29

10

championship there, but L.A. was more

11:52:31

11

Michigan.

11:52:34

12

Q.

And the NCAA didn't try to interfere

11:52:36

13

with you being paid to sign Michigan

11:52:39

14

memorabilia, did it?

11:52:41

15

A.

No.

11:52:43

16

(Exhibit Number 127

11:53:04

17

marked for identification).

11:53:06

18
19

BY MR. WIERENGA:
Q.

11:53:06

Sir, I've handed you what what's been

20

marked as Exhibit 127.

21

resume?

Is this a copy of your

11:53:22
11:53:25
11:53:25

22

A.

Yes.

11:53:25

23

Q.

Did you prepare this?

11:53:27

24

A.

Yes, I did.

11:53:28

25

Q.

Is it -- is it accurate?

11:53:28

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
196
1

record for two minutes to make -- make sure

01:47:35

2

I'm done before I say I'm done.

01:47:37

3
4

THE VIDEOGRAPHER:
1:47 p.m.

The time is

We're now off the record.

5

THE VIDEOGRAPHER:

01:47:41

(Brief recess).

6
7

1:49 p.m.

8

01:47:43
The time is

BY MR. WIERENGA:

9

Q.

We're back on the record.

Okay.

01:47:39

01:49:08
01:49:10
01:49:10

Sir, are you aware of any

01:49:13

10

instance in which you, after leaving Michigan,

01:49:15

11

have attempted to sell or license your picture

01:49:17

12

or your likeness of you playing basketball at

01:49:21

13

Michigan and the NCAA has stopped you or

01:49:24

14

attempted to stop you from doing that?

01:49:27

15

MR. BOARDMAN:

16

THE WITNESS:

17

MR. WIERENGA:

18

(Off-the-record discussion).

01:49:41

19

EXAMINATION

01:50:01

20
21

Objection to form.
No.

01:49:31

Nothing further.

BY MR. BOYLE:
Q.

01:49:28

01:49:32

01:50:01

Good afternoon, Mr. Riley.

22

Peter Boyle.

23

My name is 01:50:01

Licensing Company, also known as CLC.

I represent the Collegiate

01:50:05
01:50:08

24

A.

Okay.

01:50:08

25

Q.

Hopefully we can go through some

01:50:10

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
200
1

sites particularly.

2

under the sites.

3

Okay.

01:53:27
01:53:31

Other than those articles, is

01:53:32

4

there anything else that leads you to believe

01:53:36

5

that CLC had some role in selling NCAA

01:53:38

6

broadcast rights?

01:53:41

7

Q.

I haven't seen your name

A.

I have no -- no --

01:53:42

8

MR. BOARDMAN:

9

THE WITNESS:

10

evidence that you guys --

01:53:48

11

BY MR. BOYLE:

01:53:53

12

Q.

Objection, form.
I have no other

01:53:44
01:53:45

Can you identify any instance in which 01:53:53

13

CLC sold the rights to use your name and

01:53:56

14

likeness?

01:53:59

15

A.

No.

01:53:59

16

Q.

You testified before that there were

01:54:00

17

some trading cards of you in your Michigan

01:54:08

18

uniform, correct?

01:54:10

19

A.

Yes.

20

Q.

And you authorized Upper Deck at least 01:54:11

21

to make some of those cards, right?

01:54:11

01:54:14

22

A.

Yes.

01:54:16

23

Q.

And you got paid for that, right?

01:54:17

24

A.

Yes.

01:54:18

25

Q.

So you have in the past licensed other 01:54:19
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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
201
1

companies to use your college image for a

01:54:23

2

commercial product, right?

01:54:26

3

MR. BOARDMAN:

4

THE WITNESS:

5
6

Objection, form.
Yes.

BY MR. BOYLE:
Q.

01:54:27
01:54:28
01:54:28

And none of the defendants here

01:54:32

7

prevented you from doing that, correct?

01:54:33

8

MR. BOARDMAN:

01:54:36

9

THE WITNESS:

10
11
12

Objection, form.
No.

BY MR. BOYLE:
Q.

CLC didn't prevent you from doing

that, right?

01:54:37
01:54:37
01:54:39
01:54:41

13

A.

Right.

01:54:41

14

Q.

CLC didn't prevent you from receiving

01:54:42

15

compensation for licensing your rights to

01:54:44

16

Upper Deck, right?

01:54:46

17

A.

No, they didn't with Upper Deck.

01:54:47

18

Q.

Did CLC have any role in determining

01:54:49

19

how much you got paid for that?

01:54:52

20

A.

No.

01:54:54

21

Q.

Since leaving Michigan, what steps

01:55:04

22

have you taken to try to sell the rights to

01:55:09

23

your name and likeness?

01:55:12

24
25

A.

If I'm hiring an agent, then the

agent -- his best of his knowledge and his

01:55:19
01:55:24

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
202
1

abilities, he pretty much made calls on my

01:55:26

2

behalf or trying to sell my likeness.

01:55:30

3

Q.

Are there any instances that we

01:55:33

4

haven't discussed yet where your agent went

01:55:35

5

out and actually sold the rights to your name

01:55:38

6

and likeness and you got paid for that?

01:55:41

7

A.

Other than what we discussed?

01:55:44

8

Q.

Yes.

01:55:46

9

A.

No.

01:55:46

10

Q.

And if I remember correctly, the last

01:55:48

11

year in which you had an agent was 2002; is

01:55:52

12

that right?

01:55:55

13

A.

Yes.

01:55:55

14

Q.

So since 2002, have you done anything

01:55:57

15

to try to sell the rights to your name or

01:55:59

16

likeness?

01:56:02

17
18

A.

I mean, other than starting my

foundation.

01:56:04
01:56:07

19

Q.

Okay --

20

A.

I mean, that's -- that's sort of -- my 01:56:09

01:56:07

21

name's in the -- in the title of my

01:56:13

22

foundation.

01:56:16

23

Q.

Okay.

Other than your foundation,

01:56:16

24

since 2002, have you done anything to try to

01:56:18

25

sell the rights to your name and likeness?

01:56:20

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
213
1

THE VIDEOGRAPHER:

The time is

02:07:39

2

2:07.

3

the end of tape number two in the deposition

02:07:55

4

of Eric Riley.

02:07:57

5

off the record.

We're back on the record.

And this is

The time is 2:08 and we're now

02:07:53

02:08:02

6

(Brief recess).

7

THE VIDEOGRAPHER:

02:08:04
This is the

02:18:41

8

beginning of tape number three in the

02:18:48

9

deposition of Eric Riley.

02:18:50

10

p.m.

The time is 2:18

We're back on the record.

02:18:54

11

(Exhibit Number 134

02:18:59

12

marked for identification).

02:19:02

13

402

14

BY MR. BOYLE:
Q.

02:19:02

Mr. Riley, I've just handed you a

02:19:03

15

document that's been marked as Exhibit 134.

02:19:05

16

Could you take a look -- it's a copy of a

02:19:09

17

check made out to the High Rise Foundation and

02:19:12

18

a series of e-mails.

02:19:15

19

look at the document and let me know if you

02:19:18

20

have seen this check before in the various

02:19:20

21

e-mails?

02:19:23

Could you please take a

22

A.

Well, yes, I've seen the check.

02:19:24

23

Q.

All right.

02:19:27

And this check is a check

24

purportedly made out to the High Rise

02:19:29

25

Foundation in the amount of $1,000 and the

02:19:32

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
214

402

1

check was made out by Hoops That Help; is that

02:19:34

2

correct?

02:19:38

3

A.

Yes.

02:19:38

4

Q.

What is Hoops That Help?

02:19:38

5

A.

That's -- that's a nonprofit that

02:19:41

6

Sonny has.

02:19:47

7

Q.

Sonny Vaccaro?

02:19:49

8

A.

Sonny Vaccaro has and he donated -- he 02:19:53

9
10
11

donated money to my foundation.
Q.

And this check was made on or about

July 29th, 2010?

02:19:58
02:19:59
02:20:01

12

A.

Yeah.

02:20:03

13

Q.

And you joined this suit, when, in

02:20:04

14
15

March of 2010?
A.

02:20:08

About two years.

16

long before that.

17

this check.

18

Q.

It's been -- it was

It was definitely before

Yeah.

02:20:12
02:20:14
02:20:17

You joined the suit before Mr. and

02:20:18

19

Mrs. Vaccaro made a donation to your

02:20:22

20

foundation, right?

02:20:24

21

A.

Oh, yeah.

02:20:24

22

Q.

Okay.

02:20:25

23

Did they donate to your

02:20:26

24

402

foundation because you joined this suit?
MR. BOARDMAN:

02:20:28

25

THE WITNESS:

Objection, form.
I'm not sure the

02:20:30

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
215

402

1

reason why they donated it.

02:20:31

2

BY MR. BOYLE:

02:20:33

3

Q.

Did you ever ask them why?

4

A.

No.

5
6

I mean, we had e-mails going back 02:20:35

and forth, which this is them.
Q.

02:20:33

Yeah.

And compared to the other donations

02:20:41
02:20:44

7

that you had received up until that time, that

02:20:47

8

was by far the most significant donation you

02:20:52

9

ever received, right?

02:20:54

10

A.

Yeah, besides the commitment from

02:20:55

11

Kellogg's Foundation which I didn't get -- I

02:20:59

12

mean, I didn't receive.

02:21:01

13

Q.

How much is Kellogg's giving you?

14

A.

Well, they were.

15

year, $150,000 grant.

02:21:01

They committed three 02:21:03

But I didn't get it.

02:21:05

16

Q.

You didn't get it?

02:21:09

17

A.

No, I didn't get it.

02:21:15

18

Q.

Mr. Wierenga was asking you about

02:21:17

19

collecting documents that were relevant to

02:21:20

20

this case.

02:21:22

21

A.

Yeah.

02:21:23

22

Q.

Did you look through e-mails -- well,

02:21:24

23

Do you remember that?

strike that.

02:21:27

24

Do you have an e-mail account?

02:21:28

25

A.

02:21:29

Yeah.

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
222
1

A.

No.

02:27:21

2

Q.

You mentioned that maybe somebody had

02:27:21

3

told you that you were in a college basketball

02:27:29

4

game; is that right?

02:27:31

5

A.

Yes.

02:27:32

6

Q.

Do you know which college basketball

02:27:33

7

game you were told you were in?

02:27:35

8

A.

No.

9

Q.

Well, who told you that you were in a

10
11

I don't know the names of them.

college basketball game?
A.

02:27:36
02:27:39
02:27:41

Well, it wasn't more of just one

02:27:43

12

person, it's was just multiple -- you know, if

02:27:46

13

I'm at a camp speaking or I'm somewhere, a kid

02:27:49

14

would say I played with you in this game.

And

02:27:53

15

I would just take a mental note, okay, well --

02:27:56

16

okay.

02:27:58

17
18
19

Q.

And which game did kids tell you that

they played with you in?
A.

02:28:02

Never knew the name, never remembered

20

the name.

21

games with March Madness.

22

don't even know the name of the college games.

23

Q.

02:27:58

They just said the college game,
I'm not sure -- I

Have you ever actually seen yourself,

02:28:04
02:28:06
02:28:11
02:28:13
02:28:15

24

either yourself or an avatar of yourself in

02:28:18

25

any EA sports college game?

02:28:20

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
223
1

MR. ARAGON:

Form.

02:28:24

2

THE WITNESS:

No.

02:28:24

3
4

BY MR. BHANSALI:
Q.

02:28:24

So you don't actually know if you

02:28:25

5

appear in any EA college sports game?

02:28:26

6

MR. ARAGON:

02:28:30

7

THE WITNESS:

8

sure.

9

Form.
I don't know for

BY MR. BHANSALI:

10

No, I haven't seen it for sure.

Q.

02:28:31
02:28:32
02:28:34

When was the first time that you think 02:28:35

11

you heard that somebody at a camp or anywhere

02:28:36

12

else tell you that they played you in a

02:28:42

13

college basketball game?

02:28:44

14

MR. BOARDMAN:

15

THE WITNESS:

Object to form.
I would say the

02:28:45
02:28:48

16

first time, I can't remember the exact dates

02:28:49

17

but it's probably about six, seven years after

02:28:52

18

college.

02:28:57

19

BY MR. BHANSALI:

02:28:57

20

Q.

21

graduated?

02:28:59

22

A.

Yes.

02:28:59

23

Q.

So around 1999 timeframe?

02:28:59

24

A.

Yes, around there, yeah, '99, 2000.

02:29:01

25

Q.

And then you recall people telling you 02:29:05

Six or seven years after you

02:28:57

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
228
1

MR. BOARDMAN:

2

THE WITNESS:

Object to form.
Well, yes, if

02:33:02
02:33:03

3

it's -- it should be an option, yes.

02:33:04

4

BY MR. BHANSALI:

02:33:06

5
6

Q.

Jordan's interests would be better

served by doing his own deal?

7

MR. BOARDMAN:

8

THE WITNESS:

9

Object to form.

02:33:10
02:33:12
02:33:14

It probably would be 02:33:16
02:33:19

10

but I can imagine it would be more than 50,000

02:33:22

11

a year.

02:33:25

12

611b

but I'm not sure, you know, what he can get,

BY MR. BHANSALI:

02:33:27

13

Q.

Yeah.

Now, if you've never played an

02:33:28

14

EA game, you're not aware of EA ever using

02:33:35

15

your name, image or likeness in any of its

02:33:37

16

games, right?

02:33:42

17

MR. BOARDMAN:

Object to form.

02:33:42

18

THE WITNESS:

Well, other than

02:33:43

19

kids secondhand telling me they played me, no.

02:33:45

20

BY MR. BHANSALI:

02:33:48

21

Q.

Well, do they actually mention EA

02:33:48

22

games or do they just say they played you in

02:33:50

23

some -- some game?

02:33:52

24

MR. BOARDMAN:

25

THE WITNESS:

Object to form.
Probably not EA but

02:33:53
02:33:54

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
241
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.

24

contractor for Huseby, Inc.

I am here as an independent

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, et al. 09-cv-1967-CW
Eric Riley
November 11, 2011
242
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

______________________________

18

STEVE S. HUSEBY, CCR-B-1372

19

My Commission Expires
January 20th, 2015.

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

[phone]