Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 1 of 28 Page ID #:2579 EXHIBIT 16 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 2 of 28 Page ID Confidential #:2580 Page 1 1 2 3 4 5 6 7 IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA CASE NO. 2:19-cv-01717-RGK-AGR ----------------------------------------------------X ALEX MORGAN, MEGAN RAPINOE, BECKY SAUERBRUNN, CARLI LLOYD, MORGAN BRIAN, JANE CAMPBELL, DANIELLE COLAPRICO, ABBY DAHLKEMPER, TIERNA DAVIDSON, CRYSTAL DUNN, JULIE ERTZ, ADRIANNA FRANCH, ASHLYN HARRIS, TOBIN HEATH, LINDSEY HORAN, ROSE LAVELLE, ALLIE LONG, MERRITT MATHIAS, JESSICA McDONALD, SAMANTHA MEWIS, ALYSSA NAEHER, ELLEY O’HARA, CHRISTEN PRESS, MALLORY PUGH, CASEY SHORT, EMILY SONNETT, ANDI SULLIVAN and McCALL ZERBONI, 8 Plaintiffs, 9 v. 10 UNITED STATES SOCCER FEDERATION, INC., 11 Defendant. ----------------------------------------------------X 12 13 14 15 CONFIDENTIAL VIDEOTAPED DEPOSITION OF JILL ELLIS 16 Miami, Florida 17 January 15, 2020 18 19 REPORTED BY: BOBBIE ZELTMAN Professional Realtime Court Reporter Job Number: 174943 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 3 of 28 Page ID Confidential #:2581 Page 6 1 2 MS. WAHLKE: Lydia Wahlke on behalf of US Soccer. 3 MS. LEIDEN: And I think we 4 have one of my colleagues on the 5 phone. 6 MS. PARSIGIAN: Yes, this is 7 Jennifer Parsigian from Winston & Strawn 8 for Plaintiffs. 9 THE VIDEOGRAPHER: Will the 10 court reporter please swear in the 11 witness. 12 13 THE REPORTER: Raise your right hand, please. 14 Do you solemnly swear that the 15 testimony you're about to give will be 16 the truth, the whole truth and nothing 17 but the truth, so help you God? 18 THE WITNESS: 19 THE REPORTER: 20 Yes. Very good. JILL ELLIS, 21 having been first duly sworn by 22 Barbara R. Zeltman, Notary Public, was 23 examined and testified as follows: 24 EXAMINATION BY MS. LEIDEN: 25 Q Good morning. TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 4 of 28 Page ID Confidential #:2582 Page 155 1 2 There's just reasons. Q And so when you -- you said you 3 provided some input with respect to 4 surfaces. 5 Was that similar to the game 6 location where you would learn what the 7 surface was and then provide input, or were 8 you involved at all in kind of making the 9 decision from the start? 10 A I mean, after 2016, I don't 11 think -- I mean, I can't think that we 12 played on another turf field, so before 13 that -- I mean, the World Cup in 2015 was on 14 turf, so we had to train on turf to be ready 15 to play on turf in a world environment. 16 But I think after I guess 2016, I'm 17 trying to think, we played mainly on grass, 18 but I would be given -- I got to know the 19 stadiums to know they were grass. 20 they said we're playing here, I knew it was 21 grass. 22 all grass. 23 Q So if But after a certain point they were Were there times after you learned 24 essentially where the game was going to be 25 played that you requested that it be moved TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 5 of 28 Page ID Confidential #:2583 Page 156 1 2 to be played on grass rather than turf? A 3 I'm trying to think. I mean, I think I recall -- this is 4 maybe the end of 2015 finding out we were 5 playing potentially on a turf field and I 6 raised an issue and they actually -- I think 7 it was Georgia -- I can't remember exactly, 8 but they put grass down. 9 Q At the Georgia Dome? 10 A Yes. 11 12 13 MS. LEIDEN: Let's go off the record. THE VIDEOGRAPHER: 14 12:35 p.m. 15 record. The time is We are going off the 16 (Whereupon, a luncheon recess was 17 taken at 12:35 p.m. through 1:42 p.m.) 18 A F T E R N O O N 19 20 JILL ELLIS, resumed, having been previously 21 22 23 24 25 S E S S I O N duly sworn, was examined and testified further as follows: THE VIDEOGRAPHER: 1:42 p.m. The time is We're back on record. BY MS. LEIDEN: TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 6 of 28 Page ID Confidential #:2584 Page 157 1 Q Welcome back. 2 Before we broke for lunch, we were 3 talking about generally your responsibility 4 as head coach and different decisions that 5 were made about the team. 6 And we had discussed that you did 7 have significant input in terms of deciding 8 the opponent that the team would play, 9 right? 10 A Yes. 11 Q And then we were talking about game 12 locations and then field services. 13 And is it accurate to say that 14 US Soccer would make the decision with 15 respect to both locations and the field 16 service? 17 A Yes. 18 Q And I believe there are two 19 different things you had talked about in 20 terms of field. 21 field and one was the actual makeup of the 22 surface, whether it was artificial or turf, 23 right? One was the size of the 24 A Yes. 25 Q And US Soccer would make those TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 7 of 28 Page ID Confidential #:2585 Page 158 1 decisions and you might have input on them 2 that you would provide essentially after the 3 fact? 4 A Yes. 5 Q Okay. 6 7 The next thing I want to talk about is travel. 8 So similar question is: Did you 9 have a role in making a decision in terms 10 of, first let's say, what type of hotel 11 accommodations that you and the players 12 would have when you traveled for games? 13 A No. 14 Q How would you learn what the 15 16 accommodations would be? A So when it was Tim who was my 17 administrator, he located the hotels, and 18 then Molly did it as time, so Molly was 19 responsible for finding the hotels. 20 process, I mean, because I know she sent 21 certain parameters to operate in terms of 22 the CBA, so she would find the hotels and 23 then she would let me know. 24 25 Her And sometimes she would go scout flights out and she would go fly out there TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 8 of 28 Page ID Confidential #:2586 Page 159 1 2 to make sure it was acceptable. Q And were there any times after you 3 learned what the accommodations would be 4 that you made a request that it be changed? 5 A No. 6 Q Are you aware of any similar type 7 of requests from the players themselves in 8 terms of hotels? 9 A The only time I heard players 10 complain about a hotel was I think there was 11 construction at one hotel, and we moved them 12 from like one side of the hotel to the 13 other. 14 You know, I didn't really track a 15 lot of that, I'll be honest, but the players 16 spoke directly to Molly if there was an 17 issue. 18 But, no, I mean, I think -- again, 19 I've been retired for five and a half years. 20 I can't honestly said I've taken issue with 21 a hotel. 22 Q The next thing in terms of travel, 23 were you involved at all in the decisions as 24 to flights that yourself and the team would 25 take when traveling for games? TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 9 of 28 Page ID Confidential #:2587 Page 160 1 A No. 2 Q And when I say "flights," I mean, 3 first of all, whether the flight would be a 4 charter flight, whether it would be a 5 commercial flight and then whether within a 6 commercial flight whether any particular 7 class -- same question, in terms of all 8 those options, were you involved at all 9 before the decision was made as to what type 10 of flight? 11 A No. In 2018 for World Cup 12 qualifiers, that's when I was specifically 13 asked for charter. 14 the only time I've involved myself in 15 flights. 16 17 Q And so that was probably And was that request granted? Honored? 18 A Yes. 19 Q Other than the World Cup 20 qualifiers, were there other times that the 21 women's team took charter flights? 22 A We definitely chartered back from 23 the World Cup in Canada because we went to 24 LA. 25 Q In 2015? TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 10 of 28 Page ID Confidential #:2588 Page 161 1 A Yes. '19 as well. 2 I think we took some charters 3 around She Believes tournament -- just 4 because it was a really terrible ride -- it 5 was crazy, but other than that I don't 6 recall. 7 Q And with respect to the type of 8 flight and the class on a commercial flight, 9 were there any times other than making the 10 request specifically for the charter flights 11 that you made a request to change the 12 flights either type or time or anything with 13 respect to that? 14 15 A Gosh. Not that I can remember. No, not that I can remember. I 16 mean, I remember after once the new CBA came 17 in, the players got business class flights 18 internally which was huge because it was 19 physically so much better. 20 So but prior to that or involving 21 myself in flights or changing flights, I 22 can't remember -- would there be one time 23 where I said, Hey, can we get on an earlier 24 flight when I looked at the schedule. 25 we do the schedule a month out, so when they TSG Reporting - Worldwide But 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 11 of 28 Page ID Confidential #:2589 Page 162 1 say, Hey -- I think it's like on occasion, 2 can we train that morning and push the 3 flight back? 4 maybe occasionally. 5 hand, potentially. 6 Q You know, things like that, I can count on one And then similar question with 7 respect to the training personnel and 8 medical personnel that would -- well, first 9 just, and I think we covered this a little 10 bit already -- that were used by the team 11 generally in terms of hiring training 12 personnel, medical staff, was that something 13 you were involved in the decision making? 14 A So once James Bunce was hired in -- 15 end of 2017 -- I'm not exactly sure -- I was 16 invited in the interviews for the physical 17 therapist and new trainer, this was after 18 Rick left. 19 of involvement in that process. 20 That's been kind of my only kind In terms of securing the massage 21 therapists or trainers, that was always 22 handled out of Chicago. 23 it, Hugh O'Malley did it way back when and I 24 think it got passed on, but that was kind of 25 the administrative side that Molly dealt I think Hughie did TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 12 of 28 Page ID Confidential #:2590 Page 163 1 2 with all of that. Q And what about whether and how 3 those personnel would travel with the team 4 to games? 5 Were you involved in deciding who 6 would kind of be on the travel group to a 7 particular game? 8 A I mean, everybody that was in count 9 for the most part, you know, like we took 10 over planes, there were 50 of us when we 11 traveled with the players and staff. 12 Sometimes the staff would take -- they would 13 split non-essential personnel so always the 14 medical team would travel with the players. 15 Molly would always travel with the players, 16 but if we had to send a different group 17 because they were not essential, sometimes 18 the comp crew would take a different flight. 19 That's the only time I can recall us 20 splitting up, so to speak. 21 Q As the head coach, did you have any 22 visibility into the travel accommodations 23 for the men's team? 24 A Did I have -- 25 Q Visibility. Did you have any TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 13 of 28 Page ID Confidential #:2591 Page 164 1 2 3 4 5 knowledge of how they were traveling? A I mean, I was told. I didn't see it per se but I knew they chartered. Q You knew that the men were generally taking chartered flights? 6 A Yes. 7 Q Was there any discussion on your 8 end with respect to asking for the same 9 thing? 10 A Yes. 11 Q And who would have been involved in 12 those conversations? 13 A Tom King. 14 Q And that was between you and Tom 15 King? 16 A Yes. 17 Q And what did Mr. King respond? 18 A I think one time he said -- I don't 19 think it's in the CBA but I pushed for the 20 World Cup qualifiers and he said he'd speak 21 to Dan and it got approved. 22 Q So that would have been 2019? 23 A End of '18. 24 Q Do you recall ever making that 25 request or request for respective charters TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 14 of 28 Page ID Confidential #:2592 Page 165 1 2 flights before those World Cup qualifiers? A I think yes. I think we took a 3 couple -- yeah, it was something that I felt 4 was important because of just, you know, the 5 time involved in going domestic. 6 Q But generally speaking while you 7 were the head coach, it's your understanding 8 that the men did take more charter flights 9 than the woman overall, right? 10 A Yes. 11 Q And then similar question with 12 respect to hotel accommodations, things like 13 that: 14 types of hotels the men were staying at, 15 that type of thing? 16 A Did you have any knowledge of what Not directly, no. I mean, I think 17 Molly was pretty vigilant in checking out 18 places, and I know she talked to the men's 19 counterpart to her and would get hotel 20 information and stuff like that, so they 21 would compare. 22 Q Other than charter flights, were 23 there any other accommodations or travel 24 issues that you recall bringing to the 25 attention of US Soccer as being different TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 15 of 28 Page ID Confidential #:2593 Page 235 1 2 3 MS. KERSHAW: Just clarifying. BY MS. LEIDEN: Q And we have been talking about or 4 looking at budgets that are specific to 5 certain years, and so this document 6 aggregates certain information from fiscal 7 year 2012 through fiscal year 2020. 8 9 So there are two items in this summary. The first is hotels and from the 10 fiscal year 2012 to fiscal year 2020, the 11 expenses for the women's team has been about 12 $7.3 million and the men's team has been 13 about $10.7 million. 14 Do you see that? 15 A Yes. 16 Q On the right-hand side? 17 A Yes. 18 Q And on Air Travel, it looks like 19 the men's team is about 14.3 million and the 20 women is about 6.3 million? 21 22 A Yup. MS. KERSHAW: I'm just going to 23 object again to the foundation of 24 this document. 25 whether these numbers are accurate or She can't verify TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 16 of 28 Page ID Confidential #:2594 Page 236 1 correct. 2 3 But answer. You can still answer the question. 4 MS. LEIDEN: Well, with 5 respect -- I'm not asking her for 6 foundation. 7 As I said, this was a document 8 prepared by Plaintiffs' counsel. 9 respect, I don't think that's an So with 10 objection that has any merit. 11 with all of these, I'm not asking her to 12 authenticate a document she's never seen. 13 But again I'm asking her questions about the 14 numbers that are reflected in the 15 documents. 16 17 BY MS. LEIDEN: Q So my actual question to you after 18 all that is: Are you aware of any reason 19 why the soccer Federation has spent over 20 $3 million more on the men's team than the 21 women's team in hotels for fiscal year 2020? 22 A Do I know why? No. 23 Q And then the same question with 24 respect to why the US Soccer has spent about 25 $8 million more on the men's team than the TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 17 of 28 Page ID Confidential #:2595 Page 237 1 women's team on air travel over that same 2 period of time? 3 A No. 4 Q Are you surprised at all by these 5 6 numbers? A That word "surprise" again. 7 I look at it and I go, Okay, what 8 am I doing that year. 9 look at things, you know, am I playing a lot 10 of games. 11 12 That's kinda how I But, no, I'm not surprised. Q And you had testified a little bit 13 about this earlier, but your general 14 understanding, I believe, was that the women 15 played about 24 games or so per year? 16 A Yes. 17 Q And that generally speaking, the 18 Women's National Team has played more -- a 19 greater number of teams than the men's team 20 in this period, right? 21 22 23 A Yes. I don't know for certain, but I would imagine so, yes. Q And the Women's National Team won 24 two World Cups during this time frame, 25 right? TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 18 of 28 Page ID Confidential #:2596 Page 238 1 A Correct. 2 Q And the men's team won zero World 3 Cups during this period? 4 A Correct. 5 Q And setting aside that particular 6 document, was it your understanding while 7 you were the head coach of the Women's 8 National Team that US Soccer spent more 9 money on the men's team than the women's 10 team? 11 A Did I know that factually, no. Did 12 I assume that, yes, because I knew they got 13 charters. 14 Q So that was one specific thing that 15 you knew or were told was that the men had 16 chartered flights and the women didn't, 17 right? 18 A Correct. 19 Q Are there any other specific 20 things that you can think of that you were 21 told or found out in terms of differences 22 between funds spent on one versus the other? 23 24 25 A no. I mean, not related to the players, Coaches' salaries, yes. Q But -- That's a good point. TSG Reporting - Worldwide So coaching 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 19 of 28 Page ID Confidential #:2597 Page 239 1 salary, chartered flights, is there anything 2 else besides those two things that you are 3 aware of in terms of individual line items? 4 A No. 5 Q But I take it you would have 6 preferred those be equal? 7 MS. KERSHAW: 8 question? 9 A 10 Do I answer? Is that a Would I have preferred? 11 Jill Ellis' preference would be to 12 take more money than everybody. 13 preference would be more. 14 15 16 So my BY MS. LEIDEN: Q Right. Let me ask a clean question for the record. 17 Would it have been your preference 18 that US Soccer spend the same amount of 19 money on your salary as compared to the 20 salary of the Men's National Team head 21 coach? 22 A Correct. 23 Q And would it have been your Yes. 24 preference that US Soccer spend at least the 25 same amount of money for flights for the TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 20 of 28 Page ID Confidential #:2598 Page 240 1 Women's National Team that it did for the 2 men's team? 3 A Yes. 4 Q You can set that away. I'll shift 5 you away from numbers for a while and talk 6 about kind of the responsibilities and the 7 duties of players on the team as opposed to 8 your specific job duties. 9 Generally speaking, what's your 10 understanding of what the job duties are for 11 a player on the Women's National Team? 12 A I don't think job duties is gender 13 specific across the board, so I think they 14 would be the same responsibilities: 15 good professional, to come into camp fit, to 16 perform at a high level, to seek treatment 17 when you're injured are I think the 18 parameters of which a player has 19 responsibilities. 20 Q To be a And those things that you 21 mentioned, being a good professional, 22 fitness, performing at a high level, seeking 23 treatment for injuries, would those be the 24 same expectations for players on the Men's 25 National Team? TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 21 of 28 Page ID Confidential #:2599 Page 241 1 A Certainly. 2 Q Would you agree that one of the 3 responsibilities or requirements for a 4 player on the Women's National Team would be 5 available for team training? 6 A Yes. 7 Q And be available for games and 8 tournaments? 9 A Yes. 10 Q And to be available to travel for 11 both training and tournaments and games? 12 A Yes. 13 Q And that would be the same on the 14 men's side as well? 15 A Correct. 16 Q So generally speaking, the 17 responsibilities and requirements, I'll say 18 that, for being on the US Men's National 19 Team would be the same as the requirements 20 and responsibility for being on the Women's 21 National Team, correct? 22 A Yes. 23 Q And shifting away from duties or 24 responsibilities, would you say there's 25 skills necessary to be on the Women's TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 22 of 28 Page ID Confidential #:2600 Page 242 1 National Team? 2 A Certainly. 3 Q And could you, at a high level, 4 kind of talk about the skills that you 5 looked for as a head coach for your players? 6 A I mean, it's the four pillars of 7 the game. 8 you are looking at tactical IQ, you are 9 looking at technical proficiency, and mental 10 So you're looking at athleticism, fortitude. 11 Q 12 IQ"? 13 A And what do you mean by "tactical Meaning they have a good base 14 understanding of the game in terms of space 15 and decision-making. 16 part of the game. 17 disagrees of that even within our squad 18 because it's experienced-based, but that's 19 the thinking part of the game, yeah. 20 Q So it's the thinking There are varying And by "technical proficiency," 21 would you be referring to specific physical 22 soccer skills? 23 24 25 A Passing, shooting, dribbling, heading such. Q I believe you referred to those as TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 23 of 28 Page ID Confidential #:2601 Page 243 1 "pillars," right? 2 A Yes. 3 Q So those pillars: Athleticism, 4 tactical IQ, tactical proficiency and mental 5 fortitude, those all would be skills that 6 would be necessary for a man to be on the 7 Men's National Team, right? 8 9 10 11 A I would imagine so. I've never coached men, but I would hazard to say a player is a player. Q Do you think the players on the 12 Women's National Team are as skilled as the 13 players on the Men's National Team? 14 A Yes. 15 Q Do you think they work as hard as 16 the players on the Men's National Team? 17 A Yes. 18 Q Do you think that the US Women's 19 National Team is more popular than the US 20 Men's National Team currently? 21 22 23 A I'm not on social media but I would hazard to say yes. Q Do you have any insight into the 24 ranking or level of team that the Men's 25 National Team faces? TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 24 of 28 Page ID Confidential #:2602 Page 244 1 A In the FIFA rankings in the level 2 of opponents, I don't know the FIFA men's 3 rankings but I know the top teams. 4 know who the men play in terms of FIFA 5 ranks. 6 Q I don't But I assume you do have visibility 7 for that for the Women's National Team, 8 right? 9 A Yes. 10 Q And generally speaking, would you 11 say that the Women's National Team plays 12 fairly high-ranked opponents? 13 A Yes. 14 Q And has that been true throughout 15 16 your tenure as the head coach? A I think it's actually increased. 17 As we built in tournaments and invited the 18 elite teams into the tournaments, I actually 19 think our schedule has grown in strength 20 over time. 21 Q And sorry. Just to clarify, you 22 think that over time, the team has actually 23 faced tougher competition? 24 25 A Yeah, because we go to these tournaments and you bring in the top three TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 25 of 28 Page ID Confidential #:2603 Page 245 1 or four teams and each tournament is 2 determined by tier, so I think we've played 3 a very rigorous schedule. 4 5 6 Q Can you explain exactly what you mean by "tier"? A If you play a top ten team, the 7 elite teams in the world, if you're playing 8 mid-range. 9 hundred-something rankings so we tend to 10 11 I mean, I think there's a play the top teams as much possible. MS. LEIDEN: This document was 12 already marked at -- this was 13 Exhibit 51 at the deposition of Jay 14 Berhalter. 15 And I'll represent that, as Counsel 16 represented at Mr. Berhalter's 17 deposition, that this is a summary 18 prepared by Plaintiffs' counsel that is 19 based on documents that were produced by 20 United States Soccer Federation in this 21 case and that was pulled from 22 USSF-MORGAN-023627 through 023628 and 23 that this summarizes for 2014 and 2019 24 the Men's National Team games and the 25 Women's National Team games and the TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 26 of 28 Page ID Confidential #:2604 Page 298 1 MS. LEIDEN: 2 That's all for me. Hopefully, that means we're done. 3 MS. KERSHAW: 4 THE VIDEOGRAPHER: 5 5:21 p.m. 6 record. We're done. The time is We're going off the 7 8 9 (Whereupon, the deposition was 10 concluded at 5:21 p.m.) 11 12 ________________________ JILL ELLIS 13 14 15 Subscribed and sworn 16 to before me this 17 _____ day of ___________, 2020 18 19 __________________________ Notary Public 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document 170-18 Filed 02/20/20 Page 27 of 28 Page ID Confidential #:2605 Page 299 1 STATE OF FLORIDA ) 2 3 PAGE ______ of _____ ) ss: COUNTY OF BROWARD 4 ) I wish to make the following 5 changes, for the following reasons: 6 PAGE LINE 7 ____ ____ 8 9 ____ ____ 10 11 ____ ____ 12 13 ____ ____ 14 15 ____ ____ 16 17 ____ ____ 18 19 20 ____ ____ CHANGE: _____________________________ REASON: _____________________________ CHANGE: _____________________________ REASON: _____________________________ CHANGE: _____________________________ REASON: _____________________________ CHANGE: _____________________________ REASON: _____________________________ CHANGE: _____________________________ REASON: _____________________________ CHANGE: _____________________________ REASON: _____________________________ CHANGE: _____________________________ REASON: _____________________________ 21 22 _____________________ Witness's signature __________ Date 23 24 25 TSG Reporting - Worldwide 877-702-9580 Case 02/20/20 Page 28 of 28 Page ID #:2606 STATE OF FLORIDA ss. COUNTY OF BROWARD I, BARBARA R. ZELTMAN, a Professional Realtime Court Reporter and Notary Public, within and for the State of Florida, do hereby certify: That JILL ELLIS, the witness whose deposition is hereinbefore set forth, was duly sworn by me and that such deposition is a true record of the testimony given by the witness. I further certify that I am not related to any of the parties to this action by blood or marriage, and that I am in no way interested in the outcome of this matter. IN WITNESS WHEREOF, I have hereunto set my hand this 21st day of January, - 2020. BARBARA R. ZELTMAN Professional Realtime Reporter and Notary Public COMM NO. GG 132922 EXP: August 9, 2021 Page 300 TSG Reporting - Worldwide 877-702-9580