Case Document 173-3 Filed 02/21/20 Page 1 of 25 Page ID #:3934 EXHIBIT 10 Case 2:19-cv-01717-RGK-AGR 30(b)(6), Document Confidential 173-3 Filed 02/21/20 Page 2 of 25 Page ID #:3935 Page 1 1 SUNIL GULATI - CONFIDENTIAL 2 UNITED STATES DISTRICT COURT 3 CENTRAL DISTRICT OF CALIFORNIA 4 5 6 7 8 9 ALEX MORGAN, et al., ) ) Plaintiffs, ) ) vs. ) 2:19-cv-01717-RGK-AGR ) UNITED STATES SOCCER ) FEDERATION, INC., ) ) Defendant. ) -----------------------------) (Caption continued on the next page.) 10 11 12 * * *CONFIDENTIAL* * * VIDEOTAPED DEPOSITION OF SUNIL GULATI 30(b)(6) 13 New York, New York 14 December 17, 2019 15 16 17 18 19 20 21 22 23 Reported by: 24 KATHY S. KLEPFER, RMR, RPR, CRR, CLR 25 JOB NO. 173645 TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR 30(b)(6), Document Confidential 173-3 Filed 02/21/20 Page 3 of 25 Page ID #:3936 Page 8 1 2 SUNIL GULATI - CONFIDENTIAL SUNIL GULATI, called as a 3 witness, having been duly sworn by a Notary 4 Public, was examined and testified as 5 follows: 6 EXAMINATION BY 7 MR. KESSLER: 8 Q. Good morning, Mr. Gulati. 9 A. Good morning. 10 Q. Would you please state your name and 11 12 address for the record, please. A. Sunil Gulati, Q. Now, Mr. Gulati, I know you have been 13 14 15 deposed in the past, since I have been one of 16 the people who have deposed you, so can I assume 17 you are generally familiar with deposition 18 procedures? 19 A. Yes. 20 Q. Just to remind you of a few points: 21 If at any time my questions are unclear, please 22 ask me to rephrase them, and I will so we get a 23 clear record. 24 25 Is that acceptable to you? A. Yes. TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR 30(b)(6), Document Confidential 173-3 Filed 02/21/20 Page 4 of 25 Page ID #:3937 Page 54 1 2 3 4 SUNIL GULATI - CONFIDENTIAL Q. Do you recall that you attended this meeting? A. Since I don't remember the substance, 5 I don't recall generally, but I'm sure reading 6 this would refresh my memory. 7 I was there, then I'm sure I was there. 8 9 Q. And Mr. King said Mr. King would also be the author of these notes, to your knowledge? 10 A. I'm sure, yes. 11 Q. Was it his practice to regularly 12 prepare these notes after meetings and circulate 13 them after bargaining sessions? 14 MS. McLAUGHLIN: 15 Foundation. 16 A. 17 18 Objection. Apparently so, but I don't remember getting these subsequent to meetings. Q. Okay. So take a look at this, and 19 first of all, if you look on the first page at 20 Levine's statements -- 21 That would be Lisa Levine, who is the 22 general counsel of the -- of the USSF at the 23 time? 24 A. Yes. 25 Q. Was she one of the negotiators for TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR 30(b)(6), Document Confidential 173-3 Filed 02/21/20 Page 5 of 25 Page ID #:3938 Page 55 1 2 3 4 5 SUNIL GULATI - CONFIDENTIAL USSF at that time? A. She was one of the people involved, yes. Q. She states in the -- in her second 6 statement in the second sentence, "We understand 7 you want equal pay." 8 Do you see that? 9 A. Yes. 10 Q. Do you recall that USSF understood 11 that -- that the -- one of the bargaining 12 demands for the union in October of 2016 was for 13 equal pay with the Men's Team? 14 A. That's what it says here. I don't 15 recall that discussion, but that's what it says 16 here. 17 Q. You don't have any different 18 recollection as you're sitting here? 19 MS. McLAUGHLIN: Objection. Form. 20 A. I don't have any recollection. 21 Q. Okay. Take a look at the next page, 22 where there's a statement that's attributed -- 23 well, stay on the first page first. I'm sorry. 24 Because I want to ask you about this discussion 25 on revenues. TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR 30(b)(6), Document Confidential 173-3 Filed 02/21/20 Page 6 of 25 Page ID #:3939 Page 56 1 SUNIL GULATI - CONFIDENTIAL 2 Mr. Nichols says at the bottom of the 3 page, "We have been clear about these issues, 4 and also want T.V. sponsorship included in 5 revenue discussion." 6 7 Do you see that? A. I do, and that sentence actually makes 8 it completely unclear since the men don't have 9 those things in their agreement. But, above, 10 Ms. Levine says, "We understand you want equal 11 pay." 12 this, but also want..." Mr. Nichols says, "We've been clear about 13 14 15 So I'm not quite sure what that means, frankly. Q. Well, Ms. Levine goes on to say, 16 "There are many factors which are important to 17 us on an organizational level which factor into 18 compensation, including game revenue, ratings, 19 attendance and competitive level of play. 20 are your views on these?" 21 What In response to that, he mentioned T.V. 22 sponsorship as being things, right? 23 responding to Ms. Levine's comments. 24 A. 25 there? He's But there's an "and" in between, isn't "We have been clear about these issues, TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR 30(b)(6), Document Confidential 173-3 Filed 02/21/20 Page 7 of 25 Page ID #:3940 Page 57 1 SUNIL GULATI - CONFIDENTIAL 2 and also want T.V. sponsorship included in 3 revenue discussion." 4 Q. So you don't know what he meant there? 5 A. I don't think either of us knows what 6 7 he meant there. Q. Ms. Levine then states -- do you 8 recall this -- "We don't attribute those 9 revenues to specific teams; all falls under the 10 crest." 11 Do you see that? 12 A. I do. 13 Q. What does that refer to with respect 14 to the revenues? 15 16 MS. McLAUGHLIN: A. Objection. Form. That -- that our principal agreements, 17 principal commercial agreements include many 18 things, not either of the teams specifically, 19 but all of our teams, all of our intellectual 20 property, and a number of other assets. 21 Q. Okay. And it's correct, is it not, 22 that you do not receive reports from Soccer 23 United Marketing which attribute different 24 revenues to the Men's National Team and the 25 Women's National Team or any other items that TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR 30(b)(6), Document Confidential 173-3 Filed 02/21/20 Page 8 of 25 Page ID #:3941 Page 58 1 SUNIL GULATI - CONFIDENTIAL 2 are licensed as part of the intellectual 3 property of the Soccer Federation? 4 5 6 A. We don't receive those reports. They're not sold that way, that's correct. Q. Right. And in fact, it's correct, 7 isn't it, that it's USSF's position that it's 8 not really possible to allocate those general 9 revenues from sponsorship and broadcasting that 10 are sold by SUM to specific teams? 11 MS. McLAUGHLIN: 12 A. 13 done that. 14 15 16 17 18 Objection to form. It's USSF's position that we haven't Could one have an analysis that tried to do that? Q. Sure. But, historically, you did not do that, correct? A. We have not done that in -- I don't 19 know if it's in this meeting or the other 20 meeting I attended with similar group. 21 actually -- or in between. 22 just that and have an outside group do that, to 23 try to settle the issue of an estimation. 24 offered that to Mr. Nichols. 25 Q. We We offered to do But it was never done? TSG Reporting - Worldwide 877-702-9580 We Case 2:19-cv-01717-RGK-AGR 30(b)(6), Document Confidential 173-3 Filed 02/21/20 Page 9 of 25 Page ID #:3942 Page 59 1 SUNIL GULATI - CONFIDENTIAL 2 A. He rejected the offer. 3 Q. Okay. And so it's correct, isn't it, 4 that you're not relying on any information on a 5 revenue allocation for sponsorship and 6 broadcast -- strike that. 7 You have not historically relied on 8 any allocation of revenue for sponsorship or 9 broadcasting as a basis for distinguishing 10 between the compensation rate offered to the 11 Women's Team and the Men's Team? 12 MS. McLAUGHLIN: Objection. Form. 13 A. No, I don't agree with that statement. 14 Q. Okay. What data have you ever used in 15 your negotiations with the Women's Team or the 16 Men's Team for allocating sponsorship and T.V. 17 revenues to justify a different treatment with 18 respect to compensation? 19 A. Well, we have -- have had throughout 20 this period television ratings, which is the 21 predominant metric we would use in looking at 22 the -- the relative values of some of our 23 assets. 24 25 We have had SUM data from Nike on sales of jerseys, but not -- we haven't sat down TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 10 of 25 Page ID 30(b)(6), 173-3 Confidential #:3943 Page 60 1 SUNIL GULATI - CONFIDENTIAL 2 and said 21 percent of media contracts are 3 worth -- are attributable to the youth National 4 Teams and 51 percent to the National Teams, but 5 we've had those ratings and, therefore, know 6 what the general viewership is of our teams, 7 sure. 8 9 Q. Okay. With respect to revenue figures, is it correct that, in its entire 10 history, the USSF has never generated a single 11 report from SUM that would allocate revenues 12 from either the broadcasting agreements or from 13 the sponsorship agreements between the Men's 14 Team and the Women's Team? 15 16 MS. McLAUGHLIN: A. Objection. Form. We wouldn't -- we wouldn't get 17 anything from SUM that would allow us to do 18 that. 19 as I've said, SUM metrics that could be used for 20 that analysis if we had to at precise numbers. 21 22 23 It's not sold that way, but we know what, We didn't do that, but we could get some estimates. Q. In other words, what you're saying is 24 you might do some analysis theoretically, but 25 you've never done such an analysis; is that TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 11 of 25 Page ID 30(b)(6), 173-3 Confidential #:3944 Page 150 1 SUNIL GULATI - CONFIDENTIAL 2 THE VIDEOGRAPHER: 3 4 p.m. The time is 12:31 We're off the record. (Luncheon recess.) 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 12 of 25 Page ID 30(b)(6), 173-3 Confidential #:3945 Page 151 1 SUNIL GULATI - CONFIDENTIAL 2 AFTERNOON SESSION 3 4 5 THE VIDEOGRAPHER: p.m. We're now on the record. SUNIL GULATI, resumed and 6 testified further as follows: 7 EXAMINATION BY (Cont'd.) 8 MR. KESSLER: 9 The time is 1:21 Q. I now want to return, Mr. Gulati, to 10 the technical criteria justification that you 11 said could be -- not could be -- was one of the 12 bases for paying a different rate of 13 compensation to the Women's Team than the Men's 14 Team. 15 makes you more comfortable in terms of that. 16 17 18 And you can throw in "allege" if that What is the technical criteria that would constitute such a justification? A. Well, the technical criteria, we're 19 talking only about compensation now or all the 20 other issues that are part of this? 21 Q. Let's start first with -- with 22 compensation, because I think that's actually 23 the subject we identified you for, but -- 24 because that was your affirmative defense which 25 related to compensation, so but -- so maybe I'll TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 13 of 25 Page ID 30(b)(6), 173-3 Confidential #:3946 Page 152 1 SUNIL GULATI - CONFIDENTIAL 2 say for your individual deposition -- 3 A. Sure. 4 Q. -- how it would apply to other issues? 5 A. So, like I said earlier, it was 6 technical criteria/competition, playing related 7 issues, and so that would include what events 8 teams are playing in, where they are not 9 directly tied to additional revenue. 10 Some of them are tied to additional revenue, but events. 11 The fact that we've got, on the Men's 12 side, different levels of competition, different 13 formats of qualifying, all of those, all of 14 those, all of those things. 15 Q. So how did the different levels of 16 competition provide a basis for paying the women 17 less, as we allege? 18 A. Well, a lot of -- a lot of -- a lot of 19 the difference in compensation that are alleged 20 are regarding bonus payments, for example, and 21 that has directly to do with the level of 22 competition one is participating in. 23 Q. Okay. So what are the differences in 24 level of competition between the men's and women 25 that you are linking to the differences in the TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 14 of 25 Page ID 30(b)(6), 173-3 Confidential #:3947 Page 153 1 2 3 SUNIL GULATI - CONFIDENTIAL bonus structure? A. Well, I mean, the most obvious is, as 4 a starting point, the men and women are in 5 separate competitions under FIFA rules. 6 there is no direct comparison between -- between 7 the two teams. So 8 There can't be because they're not -- 9 they're prohibited from playing in each other's 10 competitions by FIFA and FIFA rules, but on the 11 men's side, size of the World Cup, the process 12 of qualifying, the gold cup, all of those 13 things, or where the games are played for that 14 matter. 15 On the men's side, the biggest event, 16 the process of qualifying for the World Cup, is 17 a series of home and away games. 18 playing some games in the U.S., some games in 19 Central America, some games in the Caribbean. 20 On the women's side, traditionally, So you're 21 with the exception of one event, which is 22 pre-2010, all of our qualifying games have been 23 in the United States. 24 one difference, for example. 25 Q. So that would be one -- Is it USSF's position that the Women's TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 15 of 25 Page ID 30(b)(6), 173-3 Confidential #:3948 Page 154 1 SUNIL GULATI - CONFIDENTIAL 2 game is a lower quality of play than the Men's 3 game and that that justifies the difference in 4 compensation? 5 MS. McLAUGHLIN: 6 A. 7 quality." 8 Q. 9 10 Form. I don't know what you mean by "lower The quality of the competition. Are you saying the quality of the competition is lower for the women than for the men? 11 12 Objection. MS. McLAUGHLIN: A. Same objection. Relative quality, absolute quality, 13 you know, as I read in preparing for this, as I 14 read some of the depositions, there is an 15 absolute difference, which not everyone seemed 16 to agree to, but do I think that it's less 17 attractive or less entertaining? 18 that. 19 But I'm also not saying, in terms of absolute 20 level of -- whether it's speed or strength, 21 they're the same. 22 accept that too. 23 24 25 I'm not saying Or relative quality, I'm not saying that. Q. Okay. I think most people would So I just want to pause this through. You're not saying that there's a TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 16 of 25 Page ID 30(b)(6), 173-3 Confidential #:3949 Page 155 1 SUNIL GULATI - CONFIDENTIAL 2 relative quality difference or that it's a less 3 attractive form of competition, right? 4 5 6 7 A. I'm not saying it's less or more. I'm not -- I'm not making that distinction. Q. That's not a basis for the difference in pay, those two issues? 8 A. I think that's right, yes. 9 Q. But you're saying that there's an 10 absolute difference in -- in what you're calling 11 the absolute idea -- well, let me -- 12 You're referring to an absolute 13 difference in quality based on the speed and 14 strength of the men versus the speed and 15 strength of the women? 16 A. Not just those things, but I'm 17 basically saying FIFA and the NCCA and virtually 18 every other organization have separated based on 19 genetics, biology, and so on, the two in two 20 separate categories. 21 So they're not playing in the same 22 exact competition. I think we can all agree on 23 that, and so that's what I'm really talking 24 about. 25 World Cup and vice-versa. The women aren't playing in the Men's That's point one. TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 17 of 25 Page ID 30(b)(6), 173-3 Confidential #:3950 Page 156 1 SUNIL GULATI - CONFIDENTIAL 2 Point two is that the path to -- to 3 getting to the World Cup or getting to 4 tournaments, et cetera, is different, and the 5 third part of that would be that the number of 6 countries that compete at a high level on the 7 men's side is different today than it was 50 8 years ago, and on the women's side, it's 9 improved dramatically, but it's different today 10 than it was five years ago or ten years ago, 11 substantially different. 12 Q. So you're saying that the mere fact 13 that FIFA, as you said, distinguishes based on 14 biology or genetics, and men play on a Men's 15 Team and women play on a Women's Team, that that 16 means the women are never doing equal work to 17 the men. 18 19 MS. McLAUGHLIN: Q. 20 21 Is that your position -- -- at USSF? MS. McLAUGHLIN: A. anything to that effect. 23 question there... 25 Q. Objection to form. It's not my words, and I didn't say 22 24 Objection. So if there's a You said the mere fact that they're on a different team and that FIFA distinguishes TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 18 of 25 Page ID 30(b)(6), 173-3 Confidential #:3951 Page 157 1 SUNIL GULATI - CONFIDENTIAL 2 between biology is a basis for paying the women 3 less, right? 4 A. 5 6 No, that's not what I said. MS. McLAUGHLIN: Q. Okay. Objection. Fine. 7 MS. McLAUGHLIN: 8 You mischaracterizes. 9 You're mischaracterizing his 10 Please let me get my objections stated on the record. 13 MR. KESSLER: 14 MS. McLAUGHLIN: 15 16 Wait, please. testimony. 11 12 Wait, please. Are you finished? Yes, I am. BY MR. KESSLER: Q. 17 Okay. Then I'll go the reverse. You are not claiming the mere fact 18 that they can't play on the Men's Team, you 19 know, and that FIFA makes a distinction based on 20 biology. 21 22 23 24 25 You're not claiming that's a justification for a difference in pay, correct? A. No, let's -- let's go back here. The question at the start of this was, what are the competition and technical issues TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 19 of 25 Page ID 30(b)(6), 173-3 Confidential #:3952 Page 158 1 SUNIL GULATI - CONFIDENTIAL 2 that are part of our analysis? 3 separated those into three or four different 4 things. 5 And what I We have no way to directly compare in 6 terms of a game between the two teams, for 7 example, or in the same competitions. 8 to qualifying is different. 9 competitive teams is different because of The path The number of 10 investments, because of time period, however you 11 want to call it. 12 So those are all differences in the 13 way that the sport is handled right now at FIFA 14 and the international level and, therefore, 15 across all its members. 16 Q. I'm going to ask you about the other 17 parts of your answer so you don't have to feel 18 the need to put them in. 19 now very specific, and I just want to know which 20 it is. 21 I'm just asking you Is it the position of USSF that the 22 mere fact that they -- women are not allowed to 23 play on the Men's Team and that FIFA, as you 24 stated, distinguishes based on biology, so you 25 can't be in the same competition, is that a -TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 20 of 25 Page ID 30(b)(6), 173-3 Confidential #:3953 Page 159 1 SUNIL GULATI - CONFIDENTIAL 2 is that in itself one of the justifications USSF 3 is offering for the difference in compensation 4 between the two? 5 6 MS. McLAUGHLIN: A. Objection as to form. No, it's not -- I don't think that's 7 what I've said and, you know, I'm not going to 8 answer that question with a "yes." 9 Q. 10 right? 11 A. No, you have to answer that question, I just said I'm not going to answer 12 that question with a "yes," Mr. Kessler, if you 13 wait till I finish the sentence. 14 Q. Okay. 15 A. What I've said is those are 16 differences, and so we have no way, in terms of 17 the competitive side or the technical side, of 18 saying this is exactly the same as this like you 19 might in some other areas. 20 saying. 21 Q. Okay. That's what I'm So you're not saying that, in 22 and of itself, the fact that they're not on the 23 Men's Team is a reason to give a discrimination 24 in pay? 25 you're not saying that's a reason? That's all I'm asking. TSG Reporting - Worldwide By itself, 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 21 of 25 Page ID 30(b)(6), 173-3 Confidential #:3954 Page 160 1 SUNIL GULATI - CONFIDENTIAL 2 MS. McLAUGHLIN: 3 A. Objection as to form. In and of itself, the fact that there 4 are separate teams and separate competitions, in 5 and of itself, nothing else different, no, that 6 wouldn't be -- that wouldn't be a rationale. 7 Q. Let's move on to the second thing. 8 A. So you got a "yes" on that -- 9 Q. Thank you. 10 A. -- to be clear. 11 Q. The second point you mentioned is that 12 there are different roads to qualifying for 13 events. 14 Are you saying that the women 15 deserve -- well, strike that -- that the women 16 should have a lesser rate of compensation than 17 the Men's Team because the Men's Team have to 18 win more games to get to the World Cup; is that 19 what you're saying? 20 21 MS. McLAUGHLIN: A. Objection. Form. No, what I'm saying is now we're -- as 22 I distinguished at the beginning of this, we're 23 really talking about the bonus parts of 24 compensation. 25 Q. Yes. TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 22 of 25 Page ID 30(b)(6), 173-3 Confidential #:3955 Page 161 1 2 SUNIL GULATI - CONFIDENTIAL A. And the bonuses -- let's take an 3 example. If Los Angeles Lakers are playing in a 4 game -- we'll use an individual example, which I 5 prefer you not try to change around in the next 6 question, but we can get to that, I guess. 7 LeBron James doesn't get a bonus for 8 getting 15 points and for the Lakers finishing 9 out the playoffs. The expectations for him are 10 different based on who they're playing against, 11 what -- who he is, what the level is. 12 Bonus, if we're going to look at it as 13 something either as part of guaranteed pay, 14 which it's not a bonus, I mean, like it is in 15 measuring compensation and salary cap numbers, 16 achievable bonuses and so on, so that matters 17 depending on the level of competition. 18 Q. So are you saying that because you 19 view the competition that the women face as not 20 being as strong as the competition the men face, 21 that that is a justification for giving the 22 women a lower bonus amount for their 23 achievements? 24 25 A. I'm saying that the level of achievement depends on certain conditions, one TSG Reporting - Worldwide 877-702-9580 Case 2:19-cv-01717-RGK-AGR Document Filed 02/21/20 Page 23 of 25 Page ID 30(b)(6), 173-3 Confidential #:3956 Page 162 1 SUNIL GULATI - CONFIDENTIAL 2 of which is the level of the opponent; two is 3 where is the game played; three is how many of 4 those opponents you have to play against to get 5 to a certain level; four, which is really a 6 combination of two of those, is how many other 7 teams in the world are playing at any level that 8 could give you a competitive match. 9 those things are part of it. All of 10 Q. Okay. 11 A. A bonus, if it's above expectation or 12 for a certain level of performance, when we're 13 talking about a competitive situation, has to, 14 by definition, take into account the nature of 15 the competition. 16 Q. Okay. So are you saying if -- so, 17 first of all, you agree that the Women's Team is 18 the best team in the world right now, right? 19 A. They're world champions. 20 Q. Okay. 21 And they were the last world champions as well? 22 A. That's correct. 23 Q. And are you saying if the Women's Team 24 was not so dominant over their competitors, that 25 then they would be entitled to a higher bonus TSG Reporting - Worldwide 877-702-9580 Case prnagplt Page 24 of 25 Page ID #:3957 Page 186 SUNIL GULATI - CONFIDENTIAL CERTIFICATE STATE OF NEW YORK ss COUNTY OF NEW YORK) I, Kathy S. Klepfer, a Registered Merit Reporter and Notary Public within and for the State of New York, do hereby certify: That SUNIL GULATI, the witness whose deposition is herein before set forth, was duly sworn by me and that such deposition is a true record of the testimony given by such 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 l9t day cember 2019. KATHY s. KLEPFER, RPR, RMR, CRR, CLR TSG Reporting - Worldwide 877-702-9580 Case Document 173-3 Flled 02/21/20 Page 25 of 25 Page ID Confidential Page 186 Page 187 SUNIL GULATI - CCNFIDENTIAL 1 SUNIL GULATI - CONFIDENTIAL 2 2 INDEX 3 CERTIFICATE 3 EXAMINATION 01? S. GULATI: PAGE 4 By Mr. Kessler 8 4 STATE OF NEW YORK 5 ss 6 5 COUNTY OF NEW YORK) 7 6 11 Kathy 3- Klepfer. a Registered 8 EXHIBITS: pace 7 Merit Reporter and Notary Public within and '9 Exhibit 62, Plaintifte' Rule 30(b)(6) Notice of 10 9 for the State of New York, do hereby Deposition of Defendant United States Soccer 9 certify: 10 Federation, Inc. 11 Exhibit 63, a document bearing Bates Nos. 29 10 That SUNIL the NICHOOR whose USSP_Morgan_005672 through 680 11 deposition is herein before set forth, was 12 12 duly sworn by me and that such deposition is Exhibit 64, a document bearing Bates Nos. 48 13 a true record of the testimony given by such 13 through 370 14 witness. 14 Exhibit 65, a document bearing Bates Nos. 53 15 I further certify that I am not . through 652 16 related to any of the parties to this action 15 . Exhibit 66. Chart of Revenues Minus Expenses 71 by blood or marriage and that interested in the outcome of this matter. Exhibit 67, a document bearing Bates Nos. 121 19 In witness whereof, I have hereunto 17 WNTPA 00009258 through 296 20 set my hand this 19:; er 2019. 18 21 . 19 PREVIOUSLY MARKED EXHIBITS: PAGE 22 . - 2O Berhalter Exhibit NoKATHY S. RPR. CRR, CLR 1 Plaintiffs Exhibit 9 7 23 22 Plaintiffs' Exhibit 6 110 23 Plaintiffs' Exhibit 49 116 24 24 Plaintitfs' Exhibit 38 129 25 25 Page 188 1 SUNIL GULATI - CONFIDENTIAL 2 NAME OF cuss: A. Morgan, et al. v. USSP 3 DATE OF DEPOSITION: December 17. 2019 4 NAME OF WITNESS: Sunil Gulati 5 Reason Codes: 6 1. To clarify the record. 2. To conform to the facts. 7 3. To correct transcription errors. . 8 Page Line Reason 5 From to (gala r9 9 Line Reason . 10 to 1] Line Reason to We) 12 Page Line 1'4 Reason 13 From 0 to 0 14 Page Line Reason From to 1 i312 15 Page Line Reason 16 From to 17 Page Line Reason From to 18 Page Line Reason 19 From to 20 Page Line Reason Prom to 21 Page Line Reason 22 From to 23 Page Lina Reason From to . 24 25 SUN TSG Reporting - Worldwide 877-702-9580