Campbell et al v. Facebook Inc.

Filing 184

EXHIBITS re 181 Administrative Motion to Seal Documents Accompanying Class Certification Briefs and Evidentiary Objections filed by Facebook Inc.. (Attachments: # 1 Exhibit 53 (Redacted), # 2 Exhibit 54 (Unredacted), # 3 Exhibit 55 (Redacted), # 4 Exhibit 56 (Unredacted), # 5 Exhibit 57 (Redacted), # 6 Exhibit 58 (Unredacted), # 7 Exhibit 59 (Redacted), # 8 Exhibit 60 (Unredacted), # 9 Exhibit 61 (Redacted), # 10 Exhibit 62 (Unredacted), # 11 Exhibit 63 (Redacted), # 12 Exhibit 64 (Unredacted), # 13 Exhibit 65 (Redacted), # 14 Exhibit 66 (Unredacted), # 15 Exhibit 67 (Redacted), # 16 Exhibit 68 (Unredacted), # 17 Exhibit 69 (Redacted), # 18 Exhibit 70 (Unredacted), # 19 Exhibit 71 (Redacted), # 20 Exhibit 72 (Unredacted), # 21 Exhibit 73 (Redacted), # 22 Proof of Service)(Related document(s) 181 ) (Chorba, Christopher) (Filed on 3/28/2016) Modified on 3/29/2016 (kcS, COURT STAFF).

EXHIBIT 12

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

UNITED STATES DISTRICT COURT

2

NORTHERN DISTRICT OF CALIFORNIA

3

OAKLAND DIVISION

4
5

MATTHEW CAMPBELL, MICHAEL HURLEY, )

6

and DAVID SHADPOUR,

7

)

Plaintiffs,

)

8
9
10

) Case No.
vs.
FACEBOOK, INC.,

11
12

) C 13-05996 PJH
)

Defendant.

)

_________________________________ )

13
14

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

15

SOURCE CODE

16
17

VIDEOTAPED DEPOSITION OF BENJAMIN GOLDBERG, PH.D.

18

Palo Alto, California

19

February 2, 2016

20
21
22

Reported by:

23

KELLI COMBS, CSR No. 7705

24

Job No. 2224913

25

Pages 1 - 201
Page 1
Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

"There was substantial,

2

inherent variability based on the

3

evolution of features and the

4

software over time."

5

What do you mean by "substantial" there?

6

A

11:56:44AM

11:56:56AM

Meaning that it's simply not possible to

7

conclude that all messages in the Facebook system

8

were handled the same and resulted in the same

9

processes being performed and provided the same

10

experience to the users, and -- and that the users

11

interacted the same way with the Messaging system.

12

Q

11:57:22AM

Well, you say:

13

"It's simply not possible to

14

conclude that all messages in the

15

Facebook system were handled the

16

same."

17

But what do you mean by "substantial" in

18

the context of this paragraph?

19
20
21

11:57:51AM

MR. JESSEN:

Objection; asked and

answered.

11:58:05AM
THE WITNESS:

I don't know how to quantify

22

that for you other than "substantial" meaning not

23

"insubstantial"; that it is the case that there was

24

sufficient variability that one cannot conclude that

25

the system worked the same way for -- for everybody,

11:58:33AM
Page 80

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

and that there would be lots of people for whom the

2

Messaging operated in a way other than what

3

Dr. Goldbeck has claimed to be in violation of the

4

statutes.

5

BY MR. RUDOLPH:

6
7

Q

11:58:36AM

11:58:59AM

Other than defining "substantial" as

meaning not "insubstantial," can you quantify it?

8

A

I don't have numbers to give you for that.

9

Q

Okay.

10

A

Because I don't -- I don't have access to

Why not?

11

statistics regarding, for example, database

12

failures, race conditions.

11:59:22AM

13
14

I'm not sure anybody --

(Reporter clarification.)
THE WITNESS:

Race, R-A-C-E, conditions,

15

corruption of data, and it's not true that -- I'm

16

not -- sorry.

17

statistics on -- on that in the system, the size and

18

complexity of Facebook's.

19

11:59:40AM

It's not clear to me that anybody has

My understanding is that no statistics

20

were kept on, for example, the number of users who

21

typed a URL and then deleted the preview or typed

22

the URL without hitting a space so that no preview

23

was generated.

24

tremendous variation among the way that users use

25

the system and the way the system behaved for which

11:59:57AM

There's -- there's going to be

12:00:23PM
Page 81

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1
2

no statistics are gathered.
Q

12:00:27PM

You say you didn't have access to

3

statistics regarding, for example, database

4

failures, race conditions, corruption of data.

5

Did you ask for access to those

6

statistics?

7

A

12:00:45PM

The -- the declarations actually talk

8

about that these kinds of grounds for variability

9

are not, in fact, tracked within Facebook and that

10
11

there's no way to -- to generate the statistics.
Q

12:01:06PM

Are you saying that in the declarations,

12

one of the declarants states that there are no

13

statistics on database failures?

14
15

MR. JESSEN:

Objection; documents speak

for themselves.

16

THE WITNESS:

12:01:33PM
No.

What I said was that

17

the -- one of the Facebook's declarants talked about

18

at least one source of variability for which

19

Facebook had no way of gathering statistics or did

20

not gather statistics.

21

BY MR. RUDOLPH:

22
23

Q

12:01:50PM

And I'm asking specifically about database

failures.

24

A

I don't recall.

25

Q

Okay.

12:01:58PM
Page 82

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

What about race conditions?

2

MR. JESSEN:

3
4

12:01:58PM

What's your question?

BY MR. RUDOLPH:
Q

Do any of the declarants discuss whether

5

or not Facebook has any statistics on things like

6

race conditions?

7

A

I don't recall.

12:02:08PM

I know one of the

8

declarants discusses race conditions.

9

recall exactly what he says.

10

Q

I don't

Do any of the declarants discuss whether

11

or not Facebook has statistics on database

12

corruption?

13

A

I don't recall.

14

Q

12:02:23PM

Did you look at any internal studies or

15

statistics related to race conditions?

16

A

I did not.

17

Q

Did you ask for those?

18

A

No.

19

Q

And for data corruption?

20

A

I did not.

21

Q

And for database failures?

22

A

I did not.

23

Q

12:02:55PM

And did you speak to anyone at Facebook to

24
25

12:03:07PM

determine the rate of these problems?
A

No.

12:03:25PM
Page 83

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1
2

Q

12:03:28PM

the rate of these implementation issues?

3
4

Did you do anything at all to ascertain

MR. JESSEN:

Object to the form.

Asked

and answered.

5

THE WITNESS:

No.

My experience in

6

teaching and doing research in the area of

7

distributed and parallel computing is con- -- a

8

substantial rate of variability, and these kinds of

9

12:03:38PM

failures is consistent with my experience.

10
11

BY MR. RUDOLPH:
Q

12

12:04:02PM

Okay.
You can't quantify what you mean by

13

"substantial"?

1 percent of the time, 5 percent of

14

the time, 10 percent of the time?

15

MR. JESSEN:

16

THE WITNESS:

17

Correct.

12:04:13PM

I do not have a

number for you.

18

Object to the form.

BY MR. RUDOLPH:

19
20

Q

Is there a number below which you would

say the variability is not substantial?

21

MR. JESSEN:

22

Are you just talking about the

23

12:04:22PM

parenthetical or the other parts of that sentence?

24

MR. RUDOLPH:

25

MR. JESSEN:

Objection.

No.
It's unclear, because you've

12:04:35PM
Page 84

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

been talking about race conditions, data corruption,

2

but that's not the whole sentence, so...

3

MR. RUDOLPH:

Well, fair enough.

4

variability related to race conditions, data

6

corruption or database failures.

7

THE WITNESS:

Right --

right now, I'm -- I'm -- I'm asking about

5

12:04:36PM

8

And just restate the

question.

9

12:04:44PM

BY MR. RUDOLPH:

10

Q

Is there a number below which you would

11

say these issues:

12

corruption, database failures, leads to variability

13

12:04:57PM

Race conditions, database

that is not substantial?

14

MR. JESSEN:

15

THE WITNESS:

Object to the form.
I can't give you a -- a

16

number that delineates when it is and when it is not

17

substantial.

18

12:05:15PM

BY MR. RUDOLPH:

19
20

Q

And -- and by "number," I'm -- I'm asking

for a -- a percentage of -- of the time.

21

A

I understood that.

22

Q

Right.

12:05:28PM

23

Okay.

So with respect to variability related to

24

race conditions, data corruption or database

25

failure, you really don't have any basis to say that

12:05:50PM
Page 85

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

variability related to those issues is substantial,

2

then; is that correct?

3
4

MR. JESSEN:

12:05:54PM

Objection; misstates the

testimony.

5

THE WITNESS:

Well, let me -- the basis

6

includes the sworn statements of the declarants and

7

an understanding of the complexities and the

8

difficulties in maintaining a system the size of

9

Facebook's.

12:06:00PM

And so my experience, my knowledge of

10

the technology and the sworn statements of the

11

people who built the system are the bases for my

12

conclusions.

13

BY MR. RUDOLPH:

14

Q

12:06:19PM

But you didn't do anything to investigate

15

the actual rate of things like race conditions, data

16

corruption or database failures, correct?

17

A

That's correct.

18

Q

12:06:38PM

In paragraph 15, you are discussing what

19

you characterize as Dr. Goldbeck's distinction

20

between memory and storage.

21

Did you do anything to investigate whether

22

or not such a distinction exists within the field of

23

12:07:15PM

computer science?

24
25

A

Well, I -- I cited that the Microsoft

dictionary definition of "memory," which makes clear

12:07:52PM
Page 86

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

table in the Hive database and any data

2

that it -- it contained.

3

2:35:03PM

BY MR. RUDOLPH:

4
5
6

Q

Do you have any understanding of what the

structure of the
A

table was?

2:35:15PM

I think there was some -- something that

7

was produced and attached to Dr. Goldbeck's report

8

that gave information about the

9

I don't remember the specifics.

10

Q

table.

And what is your basis for your

11

understanding that in 2011 the

12

2:36:00PM

its data were deleted?

13

A

Two things:

table and

One is the sworn statement

14

from Mr. Himel.

And I did a search in the code, the

15

2012 code, looking for use of this table, and I did

16

not find it.

17

Q

What do you mean by "use of the table"?

18

A

2:36:25PM

Adding data to the table, retrieving the

19

table, retrieving data from the table.

20

Q

21

data to it?

22

A

Both.

23

Q

And what sort of search did you perform to

24
25

Retrieving data from the table or adding

2:36:45PM

determine that?
A

I looked for code that accessed the

2:37:02PM
Page 139

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1
2
3
4
5

table, specifically database code for
accessing the
Q

table.

And describe specifically how you looked

for code that accesses the
A

2:37:04PM

table.

Doing a search on the -- on the source

6

code computer using standard tools for searching

7

2:37:27PM

code such as Grep, G-R-E-P.

8

Q

What is Grep?

9

A

It's a program in which you can specify

10

text to be searched for in files and directories.

11

It includes the ability to specify what -- specify

12

wildcards which match lots of different possible

13

strings of characters.

14

Q

15

2:37:56PM

You say:
"I looked for code that

2:38:28PM

16

accessed the

17

specifically database code for

18

accessing the

19

What -- what is database code?

20

A

table,

table."

Code in files that, for example, in this

21

case, have an HQL or a similar file extensions as

22

2:38:40PM

well as PHP code that would invoke database queries.

23

Q

Are you confident that if such code

24

existed, it would have been on the source code

25

computer that you were provided?

2:39:26PM
Page 140

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

A

There was lots of database code for

2

accessing other database tables.

3

amount of code on the source code computer, so I

4

feel -- I feel confident that if it was part of the

5

code base and in use, that it would have been on

6

2:39:38PM

that source code computer.

7
8
9
10
11

Q

12
13
14

table?

I believe that was on my second trip to

Cooley, so mid-January.
Q

2:39:55PM

When did you perform the search of the --

for code that uses the
A

There was a huge

2:40:23PM

Okay.
Why is the fact that you performed that

search not mentioned in your report?
A

No particular reason.

If I thought of it

15

while I was drafting the text -- sitting here, I

16

probably would have mentioned it.

17

just confirmed what Mr. Himel had stated.

18

Q

But it really

I believe you said you searched in code

19

from 2012.

20

you searching?

21

A

2:40:56PM

What -- what time period in 2012 were
2:41:18PM

It was the -- the last version of the code

22

on the source code computer, which was

23

December 2012.

24
25

Q

Okay.
It's possible that the code that used

2:41:33PM
Page 141

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

would have shown up in a search for

2

previous iterations of the code from previous time

3

2:41:36PM

periods, correct?

4
5
6
7

MR. JESSEN:
BY MR. RUDOLPH:
Q

2:41:51PM

You did a search for all of the class

period?

8
9

Objection.

MR. JESSEN:

Objection; calls for

speculation.

10

THE WITNESS:

I did not search, but, of

11

course, Mr. Himel has stated under oath that that

12

table did not exist during the class period.

13

2:41:56PM

BY MR. RUDOLPH:

14
15

Q

So I want to go back to, you were saying

you used tools like you call it Grep?

16

A

Grep (pronounced differently).

17

Q

Grep.

18

using Grep?

19

A

I searched for the string

20

Q

Okay.

2:42:18PM

21
22

What exactly did you search for

2:42:39PM

And that would have returned what?
A

It would have returned the list of all

23

files containing that -- that string, along with the

24

line where that string appeared in each file.

25

Q

And so, in other words, you searched for

2:43:16PM
Page 142

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

the word

the name of the table, and

2

that didn't return any results?

3

A

4

right.

5

if I had found it, I would have noted it, and I did

6

2:43:21PM

not.

7

Q

To the best of my recollection, that's
I don't recall exactly what happened.

But
2:43:35PM

And why does the fact that that search

8

returned no results demonstrate that no code within

9

Facebook was using

10

A

It was using that table because in the

11

code you specify the table you want to access by the

12

2:43:55PM

name of the table.

13
14

Q

table itself

have been stored within Facebook's system?

15
16

Where would the

MR. JESSEN:

Objection; calls for

2:44:28PM

speculation, lacks foundation.

17

THE WITNESS:

My understanding is it's in

18

their Hive database, which is a particular, very

19

large database that they maintained.

20

BY MR. RUDOLPH:

21
22

Q

2:44:48PM

Was -- were any of Facebook's databases

made available to you as part of your analysis?

23

A

The data itself, no, I don't believe so.

24

Q

You say in paragraph 45 of Nectar:

25

"I understand that it is one

2:45:38PM
Page 143

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

Messaging software is itself a device as one of

2

skill would understand it, as computer scientists

3

would understand it.

4

that's erroneous.

5
6

Q

3:33:53PM

And that's -- and I believe

You're not offering a legal opinion on

3:34:11PM

whether or not software can constitute a device?

7

A

Within a statute, for example?

8

Q

Uh-huh.

9

A

Yes, I am not offering that opinion.

10

Q

Are you aware of allegations against

11

Volkswagen that they, let's say, doctored their

12

3:35:05PM

software to get around environmental regulations?

13
14

MR. JESSEN:

Objection; outside the scope,

outside the case.

15

THE WITNESS:

From what I hear from the

16

popular press, right, they customize their software

17

so that it could detect when a test is being

18

performed and change the pollution emissions for the

19

3:35:29PM

purpose of that test.

20
21

MR. RUDOLPH:

Can you mark this as the

3:35:49PM

next exhibit.

22

(Deposition Exhibit 6 marked for

23

identification.)

24
25

BY MR. RUDOLPH:
Q

Dr. Goldberg, can you read what the title

3:36:18PM
Page 171

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1
2
3
4
5

of this article is?
A

3:36:20PM

"Volkswagen's Software Was 'Illegal Defeat

Device' German Regulator Says."
Q

This is an example of software being

referred to as a "device"; is that correct?

6

MR. JESSEN:

7

THE WITNESS:

3:36:41PM

Objection; lacks foundation.
Let me just take the time to

8

read the article so I can get the context.

9

BY MR. RUDOLPH:

10

Q

Sure.

11

A

Okay.

12

Q

This is an example of software being

13
14

3:36:54PM
So what was your -- your question?

referred to as a "device"; is that correct?
A

Well, it's software that was running on a

15

computer within the car, and in conjunction with

16

the -- with the piece of the car that -- that

17

determines the emissions -- it was in here

18

somewhere -- activating the special Eco friendly

19

mode of lower emissions.

20

And so the software running on the

21

change the emissions, is what I believe is being

23

3:39:06PM

computer in the car, together with the ability to

22

3:38:42PM

referred to as a "illegal defeat device."

24

Of course, it's in German, so it's hard to

25

know -- it's a German law, so it's hard to know what

3:39:23PM
Page 172

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1
2

the words actually mean.
Q

3:39:27PM

Would it surprise you if a governmental

3

organization defined a certain type of software as a

4

"device"?

5
6

MR. JESSEN:

Objection; lacks foundation,

3:39:52PM

incomplete hypothetical, calls for speculation.

7

THE WITNESS:

It would surprise me if the

8

government characterized software on its own without

9

actually being -- without running on something as a

10

device, but...

11

BY MR. RUDOLPH:

12
13
14

Q

3:40:12PM

All software has to run on something to

function, correct?
A

15

Correct.
MR. RUDOLPH:

Okay.

Next exhibit.

16

(Deposition Exhibit 7 marked for

17

3:40:19PM

identification.)

18
19
20
21
22

BY MR. RUDOLPH:
Q

So can you read the -- what the title of

this document is, Dr. Goldberg?
A

3:40:55PM

(Reading):
"EPA, California Notify

23

Volkswagen of Clean Air Act

24

violations.

25

used software that circumvents

Carmaker allegedly
3:41:11PM
Page 173

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

emissions testing for certain air

2

pollutants."

3
4
5

Q

3:41:13PM

Can you read the first line of the article

after the word "Washington"?
A

(Reading):

6

3:41:28PM

"Today, EPA is issuing a

7

notice of violation of the Clean

8

Air Act to Volkswagen AG, Audi AG,

9

and Volkswagen Group of America,

10

Inc., collectively referred to as

11

Volkswagen."

12

Q

13

Okay.
And then can you read the first sentence

14

of the fourth paragraph.

15

described in the NOV"?

16

3:41:43PM

A

It starts with "as
3:41:54PM

(Reading):

17

"As described in the NOV, a

18

sophisticated software algorithm on

19

certain Volkswagen vehicles detects

20

when the car is undergoing official

21

emissions testing and turns full

22

emissions controls on only during

23

the test."

24
25

Q

3:42:05PM

Okay.
And then can you read the last sentence of

3:42:16PM
Page 174

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1
2

that paragraph.
A

3:42:18PM

(Reading):

3

"The software produced by

4

Volkswagen is a 'defeat device' as

5

defined by the Clean Air Act."

6

Q

3:42:33PM

So would you agree that the EPA is

7

defining software produced by Volkswagen as a type

8

of device --

9
10
11

MR. JESSEN:

Objection.

BY MR. RUDOLPH:
Q

12

3:42:49PM

-- within the meaning of a statute?
MR. JESSEN:

Objection; lacks foundation,

13

calls for speculation, document speaks for itself,

14

also irrelevant.

15

if you want.

16

But you can certainly read this,

THE WITNESS:

3:43:01PM
I -- I read this as them

17

saying that the software running on the Volkswagen

18

computer is a defeat device.

19

being -- perhaps being imprecise, but the software

20

on its own can't defeat anything.

21

BY MR. RUDOLPH:

I think they're

22

Q

Imprecise by whose lights?

23

A

3:43:20PM

Meaning who would consider this imprecise,

24
25

this press release?
Q

Uh-huh.

3:43:36PM
Page 175

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

A

Someone in computer science would

3:43:38PM

2

consider -- might consider this imprecise.

3

clear from the context they're talking about the

4

software running on the Volkswagen computer.

5

Q

It's

So the statement:

6

3:44:03PM

"In my 33 years as a computer

7

scientist, I have never heard the

8

term 'device' used to refer to

9

software."

10

Is that statement still true?

11

MR. JESSEN:

12

THE WITNESS:

3:44:11PM

Object to the form.
Well, it's certainly true

13

when I -- I wrote it.

14

refer to software as a device, it's -- it's an odd

15

characterization, but the way I read it is as

16

software running on the Volkswagen computer was a

17

device, which I don't disagree with.

18

this language is not language you would see in

19

computer science itself.

20

BY MR. RUDOLPH:

21
22

Q

To the extent that this does

3:44:30PM

But this --

3:44:47PM

So you say:
"But the way I read it is as

23

software running on the Volkswagen

24

computer was a device, which I

25

don't disagree with."

3:44:55PM
Page 176

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE
1

Why does the fact that the software was

2

running on the device lead you to not disagree with

3

the statement that "The software produced by

4

Volkswagen is a defeat device"?

5

MR. JESSEN:

3:45:00PM

Objection.

I'll just object

6

to this entire line as lacking foundation, calling

7

for speculation.

8

3:45:17PM

BY MR. RUDOLPH:

9
10

Q

I'm sorry.

Yeah.

Thanks.

Why does the fact that the software was

11

running on a computer lead you to not disagree with

12

the statement that "the software produced by

13

Volkswagen is a defeat device"?

14

MR. JESSEN:

15

THE WITNESS:

3:46:08PM

Object to the form.
Because lots of devices run

16

software, and so if you read that as I do, that what

17

they're saying is that the software, when it runs on

18

the -- on the computer, constitutes a device because

19

there's something physical there, then that would be

20

a normal use of the term "device" because you have

21

3:46:25PM

an actual, physical device.

22
23
24
25

MR. RUDOLPH:

3:46:47PM

How long have we been going?

Let's take a break.
THE VIDEOGRAPHER:

This marks the end of

Disk 3 to the deposition of Dr.

Benjamin Goldberg,

3:47:11PM
Page 177

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
SOURCE CODE

1
2
3

I, the undersigned, a Certified Shorthand
Reporter of the State of California, do hereby certify:
That the foregoing proceedings were taken

4

before me at the time and place herein set forth; that

5

any witnesses in the foregoing proceedings, prior to

6

testifying, were administered an oath; that a record of

7

the proceedings was made by me using machine shorthand

8

which was thereafter transcribed under my direction;

9

that the foregoing transcript is a true record of the

10
11

testimony given.
Further, that the foregoing pertains to the

12

original transcript of a deposition in a Federal Case,

13

before completion of the proceedings, a review of the

14

transcript [ ] was [X] was not requested.

15

I further certify I am neither financially

16

interested in the action nor a relative or employee of

17

any attorney or any party to this action.

18
19

IN WITNESS WHEREOF, I have this date
subscribed my name.

20
21

Dated: 2/3/16

22
23
24

<%signature%>
KELLI COMBS

25

CSR No. 7705
Page 201
Veritext Legal Solutions
866 299-5127