Case 2:19-cv-01717-RGK-AGR Document 171-50 Filed 02/20/20 Page 1 of 6 Page ID
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·1· · · ·IN THE UNITED STATES DISTRICT COURT
·2· · · FOR THE CENTRAL DISTRICT OF CALIFORNIA
·3· · · · · · NO. 2:19-cv-01717-RGK-AGR
·4·
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·5
· ·
·6
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·7
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·8·

·--------------------------------X
·ALEX MORGAN, et al.,
· · · · · · · · · Plaintiffs,
· · · · · · ·VS.
·UNITED STATES SOCCER
·FEDERATION, INC.,

·9· · · · · · · · · · Defendant.
· · ·--------------------------------X
10
11
12
13· · · · · · · · · · DEPOSITION
14· · · · · · · · · · · · OF
15· · · · · · · · · MEGAN RAPINOE
16· · · · · · Thursday, January 16, 2020
17· · · · · · · · 620 Eighth Avenue
18· · · · · · · · New York, New York
19
20
21· ·Reported by:
· · ·AYLETTE GONZALEZ, RPR, CLR, CCR
22· ·JOB NO. 175029
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24
25

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·1· ·had had $25,000 higher in annual base
·2· ·compensation for the contracted players, which
·3· ·was draped to 100,000 in their original
·4· ·proposal and then in the contract stayed at
·5· ·100,000.· So that could be the reason for the
·6· ·resulting discrepancies.
·7· · · · ·Q.· ·It suggests that the parties were
·8· ·making trade-offs in different line items in
·9· ·order to reach on overall deal, doesn't it?
10· · · · ·A.· ·You could say that.
11· · · · ·Q.· ·And so you don't know what kind of
12· ·win or tie bonus you could have achieved if
13· ·you had reduced that annual-based compensation
14· ·even further than $100,000, do you?
15· · · · ·A.· ·I don't know.· I suppose if it went
16· ·down or up, the other numbers would change as
17· ·well.
18· · · · ·Q.· ·Okay.· Do you see in proposal
19· ·number 17 that there's no signing bonus being
20· ·proposed in that document?
21· · · · ·A.· ·Exhibit 17?
22· · · · ·Q.· ·Yep.
23· · · · ·A.· ·I see that.
24· · · · ·Q.· ·Do you see that there is a signing
25· ·bonus proposed in Exhibit 18?
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·1· ·appearances suggests that its decision about
·2· ·how to pay for commercial appearances is not
·3· ·motivated by sex?
·4· · · · · · · MS. SPANGLER:· Objection; calls
·5· · · · ·for speculation.
·6· · · · ·A.· ·No, I wouldn't necessarily say
·7· ·that.
·8· · · · ·Q.· ·Ms. Rapinoe, do you remember doing
·9· ·an interview with Pod Save America last year?
10· · · · ·A.· ·Yes.
11· · · · · · · (Rapinoe Exhibit 29, Transcript of
12· · · · ·Video @ USSF_Morgan_042310 was marked
13· · · · ·for identification, as of this date.)
14· · BY MR. STOLZENBACH:
15· · · · ·Q.· ·We produced in litigation in this
16· ·case video from that interview that I think
17· ·Pod Save America's Twitter account tweeted
18· ·out.· It's labeled in the production
19· ·USSF_Morgan_042310.· I presented you with a
20· ·typed transcript as it were of what you said
21· ·in that interview on that video that was on
22· ·the Twitter account.· I assume you can't sit
23· ·here today and tell me you remember exactly
24· ·what you said and whether this transcript is
25· ·accurate; is that fair?
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·1· · · · ·A.· ·That is fair, yes.
·2· · · · ·Q.· ·So I'm going to play it for you.
·3· ·And you can listen to it and read along and
·4· ·just see if you agree that we've gotten it
·5· ·correct, that we've transcribed it accurately,
·6· ·okay?
·7· · · · ·A.· ·Okay.
·8· · · · · · · (Audio played.)
·9· · · · ·Q.· ·Does Exhibit 29 accurately
10· ·transcribe your remarks in the interview I
11· ·just played?
12· · · · ·A.· ·Seems so, yes.
13· · · · ·Q.· ·I want to focus on the beginning of
14· ·Exhibit 29, where it says, "It's a complex
15· ·argument.· Our pay structure is different.· We
16· ·play different games.· We're different
17· ·rankings in the world, like it's just apples
18· ·to oranges."
19· · · · · · · "Our pay structure is different,"
20· ·when you said that, you were referring to the
21· ·pay structures of the Men's National Team
22· ·versus the Women's National Team, correct?
23· · · · ·A.· ·Yes.
24· · · · ·Q.· ·And when you said, "We play
25· ·different games," that was a reference to a
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·1· ·comparison between the Men's National Team and
·2· ·the Women's National Team, right?
·3· · · · · · · MS. SPANGLER:· Objection to the
·4· · · · ·form, but you can answer that if you
·5· · · · ·can.
·6· · · · ·A.· ·Play different games, like
·7· ·sometimes they play like in Gold Cup and we're
·8· ·playing Tournament of Nations or like that, I
·9· ·think is -- I think is what I meant at the
10· ·time, but I can't say for certain exactly what
11· ·I meant.
12· · · · ·Q.· ·Okay.· In any event, you were
13· ·referring to, when it says "we play different
14· ·games," the "we" was the Women's National Team
15· ·compared to the Men's National Team, right?
16· · · · ·A.· ·I think so.
17· · · · ·Q.· ·"We're different rankings in the
18· ·world."· That was you also comparing the Men's
19· ·National Team to the Women's National Team,
20· ·right?
21· · · · ·A.· ·Right.
22· · · · ·Q.· ·"And it's just apples to oranges,"
23· ·was your description of trying to compare the
24· ·Men's National Team to the Women's National
25· ·Team, right?
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·1· · · · ·A.· ·Seems like it, yeah.
·2· · · · · · · (Rapinoe Exhibit 32, Caitlin
·3· · · · ·Murray tweet was marked for
·4· · · · ·identification, as of this date.)
·5· · BY MR. STOLZENBACH:
·6· · · · ·Q.· ·Exhibit 32 is a tweet by Caitlin
·7· ·Murray.· Do you know Ms. Murray?
·8· · · · ·A.· ·I know of her.
·9· · · · ·Q.· ·Okay.· She tweeted out -- you can
10· ·see there a quote that she attributes to you.
11· ·Is that an accurate quotation of something
12· ·that you said or wrote to her?
13· · · · ·A.· ·I think that's accurate, as far as
14· ·I cannot confirm the validity of it the
15· ·document, but...
16· · · · ·Q.· ·But that's an accurate quotation of
17· ·you, true?
18· · · · ·A.· ·I think so.
19· · · · ·Q.· ·Do you recall John Harkes' wife
20· ·e-mailing you about the concept of hiring a
21· ·lobbyist?
22· · · · ·A.· ·No.
23· · · · ·Q.· ·Have you ever engaged a lobbyist?
24· · · · ·A.· ·Personally?
25· · · · ·Q.· ·Yeah.
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