EXHIBIT a REDACTED VERSION of DOCUMENT PROPOSED to BE FILED UNDER SEAL Case 2:19-Cv-01717-RGK-AGR Document 226-2 Filed 03/31/20 Page 2 of 26 Page ID #:8801

Case 2:19-cv-01717-RGK-AGR Document 226-2 Filed 03/31/20 Page 1 of 26 Page ID #:8800

EXHIBIT A REDACTED VERSION OF DOCUMENT PROPOSED TO BE FILED UNDER SEAL Case 2:19-cv-01717-RGK-AGR Document 226-2 Filed 03/31/20 Page 2 of 26 Page ID #:8801

1 WINSTON & STRAWN LLP Jeffrey L. Kessler (admitted pro hac vice) 2 [email protected] David G. Feher (admitted pro hac vice) 3 [email protected] 200 Park Avenue 4 New York, New York 10166 Telephone: (212) 294-6700 5 Facsimile: (212) 294-4700 6 Cardelle B. Spangler (admitted pro hac vice) [email protected] 7 35 West Wacker Drive Chicago, Illinois 60601 8 Telephone: (312) 558-5600 Facsimile: (312) 558-5700 9 Attorneys for Plaintiffs 10 LATHAM & WATKINS LLP 11 Jamie L. Wine (Bar No. 181373) E-mail: [email protected] 12 885 Third Avenue New York, NY 10022 13 Phone: (212) 906-1200 Facsimile: (212) 751-4864 14 Michele D. Johnson (Bar No. 198298) 15 E-Mail: [email protected] 650 Town Center Drive, 20th Floor 16 Costa Mesa, CA 92626 Phone: (714) 540-1235 17 Facsimile: (714) 755-8290 18 Attorneys for Defendant UNITED STATES SOCCER FEDERATION, INC. 19 *Additional counsel identified on signature page 20 UNITED STATES DISTRICT COURT 21 CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION 22 Case No. 2:19-cv-01717-RGK-AGR 23 ALEX MORGAN, et al., JOINT WITNESS LIST 24 Plaintiffs/Claimants, Discovery Cutoff: February 6, 2020 25 v. Pre-trial Conference: April 20, 2020 Trial: May 5, 2020 26 UNITED STATES SOCCER FEDERATION, INC., 27 USSF/Respondent. 28

JOINT WITNESS LIST CASE NO. 2:19-CV-01717-RGK-AGR Case 2:19-cv-01717-RGK-AGR Document 226-2 Filed 03/31/20 Page 3 of 26 Page ID #:8802

1 Pursuant to Federal Rule of Civil Procedure 26(a)(3)(A), Local Rule 16-5 of the 2 Central District of California, and this Court’s Order for Jury Trial (Dkt. No. 60), 3 plaintiffs Alex Morgan, et al. (collectively, “Plaintiffs”) and Defendant United States 4 Soccer Federation, Inc. (“U.S. Soccer” or “USSF”), hereby submit the following list of 5 witnesses who may be called to testify at trial in this matter. 6 I. Plaintiffs’ Witness List 7 This list identifies the witnesses whom Plaintiffs intend to call, or may call, at 8 trial, exclusive of any witnesses whom may be called for rebuttal or impeachment. 9 Plaintiffs reserve the right to call any witness on Defendant USSF’s witness list, if those 10 witnesses are not in fact called by USSF. Plaintiffs expressly reserve the right to 11 supplement this list at any time before trial, and the right to object to any supplemental 12 witnesses identified by USSF. Plaintiffs further reserve the right to call or refrain from 13 calling any of the witnesses on this list. 14 U.S. Soccer notes that it seeks to exclude Plaintiffs’ expert witnesses Cook and 15 Goldberg (listed in the below chart) for the reasons stated in U.S. Soccer’s motions in 16 limine Nos. 3 and 5. 17

18 Witness Name/Address Brief Statement of Testimony Time Estimate 19 Alex Morgan Alex Morgan is a plaintiff class Live Witness c/o Jeffrey Kessler member and also one of four class 20 Plaintiffs: 1.25 Winston & Strawn LLP representatives. Of the four class hours 21 200 Park Avenue representatives, she has been New York, NY 10166 employed as a soccer player by USSF 22 USSF: 1.25 Tel.: (212) 294-6700 for the shortest period of time, since hours 23 2010. In 2017, Ms. Morgan played soccer on loan to the French soccer 24 This witness club Lyon. appears in both 25 Plaintiffs’ list Ms. Morgan serves on the Collective and USSF’s list. 26 The times listed Bargaining Committee, Medical in Plaintiffs’ list 27 Committee, and NWSL Committee for cover the total the United States Women’s National time expected 28 for the

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1 Witness Name/Address Brief Statement of Testimony Time Estimate Team Players Association witness’s 2 testimony at (“WNTPA”). Ms. Morgan participated trial. 3 in collective bargaining negotiations 4 with USSF in November 2015 and December 2016. 5 6 Ms. Morgan will testify about the collective bargaining negotiations 7 between USSF and the union for the 8 U.S. Senior Women’s National Soccer Team (“WNT”) that she attended; the 9 terms of the WNTPA’s collective 10 bargaining agreements with USSF; the WNT’s working conditions, including 11 mode of transportation to and from 12 games (and the benefits and negatives of each option) and field surfaces for 13 WNT matches (and the benefits of a 14 grass field surface versus an artificial turf surface); a WNT player’s job 15 responsibilities; compensation from 16 USSF for WNT play; USSF’s treatment of the WNT; and facts 17 evidencing USSF’s intent to 18 discriminate.

19 20

25 Christen Press1 Christen Press is a plaintiff class Live Witness 26 1 27 Plaintiff class member Alex Morgan may be unavailable at trial because of her pregnancy, and in the event that Ms. Morgan is unable to attend trial, Plaintiffs intend 28 to call Christen Press in her place. Plaintiffs do not intend to call both Ms. Morgan and

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1 Witness Name/Address Brief Statement of Testimony Time Estimate

2 c/o Jeffrey Kessler member. She is not a class Plaintiffs: 1.25 Winston & Strawn LLP representative. Ms. Press has been 3 hours 200 Park Avenue employed as a soccer player by USSF 4 New York, NY 10166 since 2012. USSF: 0.75 Tel.: (212) 294-6700 5 hours Ms. Press served as a player representative for the WNTPA during 6 This witness collective bargaining with USSF over appears in both 7 the 2017-2021 WNT collective Plaintiffs’ list bargaining agreement. She attended and USSF’s list. 8 The times listed collective bargaining negotiations and in Plaintiffs’ list 9 discussions in December 2016 cover the total (including one meeting where the only time expected 10 for the class representative present was Ms. witness’s 11 Morgan) and February 2017. Unlike testimony at 12 the four class representatives, Ms. trial. Press did not file an EEOC Charge of 13 Discrimination against USSF in 2016.

14 If called, Ms. Press will testify about 15 the WNTPA’s collective bargaining 16 negotiations with USSF that she attended; the terms of the WNTPA’s 17 collective bargaining agreements with 18 USSF; the WNT’s working conditions, including mode of 19 transportation to and from games and 20 field surfaces for WNT matches; a WNT player’s job responsibilities; 21 compensation from USSF for WNT 22 play; USSF’s treatment of the WNT; facts evidencing USSF’s intent to 23 discriminate, including specific 24 discriminatory statements made by USSF negotiators during negotiations; 25 and the WNT players’ use of 26 “equitable” during negotiations over the 2017-2021 WNT collective 27

28 Ms. Press as witnesses.

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1 Witness Name/Address Brief Statement of Testimony Time Estimate 2 bargaining agreement. Megan Rapinoe Megan Rapinoe is a plaintiff class Live Witness 3 c/o Jeffrey Kessler member and also one of four class Plaintiffs: 1.25 4 Winston & Strawn LLP representatives. She has been hours 200 Park Avenue employed as a soccer player by USSF 5 New York, NY 10166 since 2006. USSF: 1.25 6 Tel.: (212) 294-6700 hours Ms. Rapinoe previously served on the 7 Collective Bargaining Committee and 8 Commercial Committee for the WNTPA. Ms. Rapinoe attended 9 collective bargaining negotiations in 10 February 2016, March 2016, June 2016, February 2017, and April 2017. 11 12 In 2007 and 2008, Ms. Rapinoe suffered two significant knee injuries 13 that prevented her from training or 14 playing with the WNT.

15 Ms. Rapinoe will testify about the 16 WNTPA’s collective bargaining negotiations with USSF that she 17 attended; the terms of the WNTPA’s 18 collective bargaining agreements with USSF; the WNT’s working 19 conditions, including mode of 20 transportation to and from games and field surfaces for WNT matches; a 21 WNT player’s job responsibilities; 22 compensation from USSF for WNT play; USSF’s treatment of the WNT; 23 and facts evidencing USSF’s intent to 24 discriminate, including specific discriminatory statements made by 25 USSF negotiators during negotiations. 26 Carli Lloyd Carli Lloyd is a plaintiff class member Live Witness c/o Jeffrey Kessler and also one of four class 27 Plaintiffs: 1.25 Winston & Strawn LLP representatives. Of the four class hours 28

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1 Witness Name/Address Brief Statement of Testimony Time Estimate

2 200 Park Avenue representatives, she has been New York, NY 10166 employed as a soccer player by USSF USSF: 1.25 3 Tel.: (212) 294-6700 for the longest period of time, since hours 4 2005.

5 Ms. Lloyd serves on the NWSL 6 committee for the WNTPA and has not served on any other committee for 7 the WNTPA. 8 Ms. Lloyd will testify about the 9 WNTPA’s collective bargaining 10 negotiations with USSF that she attended; the terms of the WNTPA’s 11 collective bargaining agreements with 12 USSF; the WNT’s working conditions, including mode of 13 transportation to and from games and 14 field surfaces for WNT matches; a WNT player’s job responsibilities; 15 compensation from USSF for WNT 16 play; USSF’s treatment of the WNT; and facts evidencing USSF’s intent to 17 discriminate. 18 Becky Sauerbrunn Becky Sauerbrunn is a plaintiff class Live Witness c/o Jeffrey Kessler member and also one of four class 19 Plaintiffs: 2.5 Winston & Strawn LLP representatives. She has been hours 20 200 Park Avenue employed as a soccer player by USSF New York, NY 10166 since 2008. 21 USSF: 1.25 Tel.: (212) 294-6700 hours 22 Ms. Sauerbrunn attended several collective bargaining negotiations 23 culminating in the execution of the 24 WNTPA’s 2017-2021 collective bargaining agreement with USSF. 25

26 Ms. Sauerbrunn is a player representative for the WNTPA. 27

28 Ms. Sauerbrunn will testify about the

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1 Witness Name/Address Brief Statement of Testimony Time Estimate 2 WNTPA’s collective bargaining negotiations with USSF that she 3 attended; the terms of the WNTPA’s 4 collective bargaining agreements with USSF; the WNT’s working 5 conditions, including mode of 6 transportation to and from games and field surfaces for WNT matches; a 7 WNT player’s job responsibilities; 8 compensation from USSF for WNT play; USSF’s treatment of the WNT; 9 and facts evidencing USSF’s intent to 10 discriminate. 11 12 13 14 15 16 Dr. Finnie Cook Dr. Cook is an economist who Live Witness 17 c/o Jeffrey Kessler conducts economic analyses of lost Plaintiffs: 3 18 Winston & Strawn LLP wages and benefits. She is Plaintiffs’ hours 200 Park Avenue damages expert. 19 New York, NY 10166 USSF: 2.0 20 Tel.: (212) 294-6700 Dr. Cook will testify on the backpay hours damages suffered by plaintiff 21 members of the Equal Pay Act and 22 Title VII classes, and the corresponding pre-judgment interest 23 and liquidated damages also due. 24 Dr. Caren Goldberg Dr. Goldberg is a professor of human Live Witness 25 c/o Jeffrey Kessler resource management and an expert in Plaintiffs: 3 26 Winston & Strawn LLP this field. She is Plaintiffs’ human hours 200 Park Avenue resources expert. 27 New York, NY 10166 USSF: 2.0 28

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1 Witness Name/Address Brief Statement of Testimony Time Estimate

2 Tel.: (212) 294-6700 Dr. Goldberg will testify on whether hours USSF’s human resource practices fell 3 below standard and acceptable human 4 resource practice with respect to USSF’s treatment of WNT players in 5 connection with various aspects of 6 their employment with USSF, including their working conditions and 7 complaints of unequal and/or 8 discriminatory treatment.

9 10

11 12

13 Dr. Roger Noll*2 Dr. Noll is an economist and a Live Witness 14 c/o Jeffrey Kessler professor of economics. He is Plaintiffs: 2 Plaintiffs’ rebuttal expert. 15 Winston & Strawn LLP hours 200 Park Avenue 16 New York, NY 10166 Dr. Noll will rebut testimony from Ms. USSF: 1.50 Irwin regarding revenue generated by 17 Tel.: (212) 294-6700 hours the WNT and the U.S. Senior Men’s 18 National Soccer Team (“MNT”), respectively, and whether revenue 19 differences could justify differences in 20 compensation for the two teams. He will also rebut the testimony of 21 USSF’s expert, Dr. Justin McCrary, 22 who is expected to testify on whether WNT players receive a lower rate of 23 pay under their collective bargaining 24 agreement compared to what MNT players are compensated under their 25 collective bargaining agreement with 26 USSF. Dr. Noll will also rebut 27 2 Plaintiffs may call Dr. Noll on rebuttal depending on the outcome of their Daubert 28 motion and motion in limine on USSF’s expert testimony. See Dkt. Nos. 167 and 216.

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1 Witness Name/Address Brief Statement of Testimony Time Estimate

2 testimony from Dr. McCrary regarding whether economic risk in 3 the WNT’s and MNT’s collective 4 bargaining agreements makes the two agreements incomparable. 5 6

7 8

9 10 United States Soccer USSF’s 30(b)(6) testimony will cover By Deposition 11 Federation through the differences between the terms of Video 12 30(b)(6) Designees Jay the relevant collective bargaining Berhalter, Sunil Gulati, agreements between the MNT and Plaintiffs: 5 13 and Tom King USSF and the WNT and USSF and the hours 14 c/o Brian Stolzenbach negotiations of the collective Seyfarth Shaw LLP bargaining agreements. The 30(b)(6) USSF: 3.0 15 233 S. Wacker Drive testimony will also cover USSF’s hours 16 Suite 8000 finances, revenues, budgeting, and Chicago, IL 60606 marketing and sponsorship issues. It 17 Tel.: (312) 460-5551 will also cover USSF’s organizational 18 structure, operations of the MNT and WNT, and its decisions regarding the 19 treatment of the MNT and WNT, 20 including playing surfaces on which both the MNT and WNT play and the 21 hotel and travel arrangements for each 22 team.

23 Sunil Gulati Mr. Gulati is the former President of Live or by 24 c/o Brian Stolzenbach USSF. He serves on USSF’s board of Deposition Seyfarth Shaw LLP directors. Video 25 233 S. Wacker Drive 26 Suite 8000 Mr. Gulati will testify on revenues Plaintiffs: 3 Chicago, IL 60606 generated by the WNT and the MNT hours 27 Tel.: (312) 460-5551 for USSF, and whether these revenue 28

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1 Witness Name/Address Brief Statement of Testimony Time Estimate

2 figures were the basis for the alleged USSF: 4.0 pay differential between WNT players hours 3 and MNT players. He will also testify 4 on USSF’s responses to and policies This witness on complaints of discrimination. He appears in both 5 Plaintiffs’ list will also testify on USSF’s collective and USSF’s list. 6 bargaining negotiations with WNT The times listed players. in Plaintiffs’ list 7 cover the total time expected 8 for the witness’s 9 testimony at trial. 10

11 Jay Berhalter Mr. Berhalter is the former Chief Live or by 12 c/o Brian Stolzenbach Commercial Officer of USSF. He Deposition Seyfarth Shaw LLP resigned from this position in Video 13 233 S. Wacker Drive February 2020. 14 Suite 8000 Plaintiffs: 1 Chicago, IL 60606 Mr. Berhalter will testify on the hour 15 Tel.: (312) 460-5551 economic values to USSF of the 16 WNT’s and MNT’s respective USSF: 1.50 contributions; the marketing and hours 17 promotion of the WNT and the MNT; 18 USSF’s sponsorship agreements relating to the WNT and the MNT; 19 USSF’s policies and practices with 20 respect to the WNT and the MNT; the respective job duties of WNT and 21 MNT players; and USSF’s 22 relationship with the National Women’s Soccer League. 23 Carlos Cordeiro Mr. Cordeiro is the President of USSF Live or by 24 c/o Brian Stolzenbach and he also serves on USSF’s board of Deposition 25 Seyfarth Shaw LLP directors. Video 233 S. Wacker Drive 26 Suite 8000 Mr. Cordeiro will testify on whether Plaintiffs: 2 27 Chicago, IL 60606 he or any other USSF board members hours Tel.: (312) 460-5551 have raised the issue of whether WNT 28

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1 Witness Name/Address Brief Statement of Testimony Time Estimate

2 players are not treated equally with USSF: 1.25 MNT players. He will also testify on hours 3 USSF’s policies and practices for 4 complying with the Equal Pay Act and Title VII. He will also testify on the 5 process of preparing WNT and MNT 6 team budgets.

7 8

9 10 Tom King Mr. King is USSF’s Managing Live or by c/o Brian Stolzenbach Director of Administration. Deposition 11 Seyfarth Shaw LLP Video 12 233 S. Wacker Drive Mr. King will testify on the terms and Suite 8000 application of the MNT union’s and Plaintiffs: 3 13 Chicago, IL 60606 WNTPA’s respective collective hours 14 Tel.: (312) 460-5551 bargaining agreements with USSF, including any differences between USSF: 4.50 15 these agreements on compensation and hours 16 other terms contained therein. He will also testify on the administration of 17 This witness the WNT and the MNT, including appears in both Plaintiffs’ list 18 with respect to hotel and travel and USSF’s list. accommodations. 19 The times listed in Plaintiffs’ list cover the total 20 time expected for the 21 witness’s testimony at 22 trial. 23 Pinky Raina Pinky Raina is USSF’s Chief Live or by 24 c/o Brian Stolzenbach Financial Officer. Deposition 25 Seyfarth Shaw LLP Video 233 S. Wacker Drive She will testify on USSF’s budgeting 26 Suite 8000 process, financial records relating to Plaintiffs: 1 27 Chicago, IL 60606 revenue and expenses for the WNT hour Tel.: (312) 460-5551 and MNT, and financial record- 28

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1 Witness Name/Address Brief Statement of Testimony Time Estimate

2 keeping. USSF: 2.0 hours 3 4 This witness appears in both 5 Plaintiffs’ list and USSF’s list. 6 The times listed in Plaintiffs’ list 7 cover the total time expected 8 for the witness’s 9 testimony at trial. 10

11 12

15 Jill Ellis Jill Ellis the former head coach of the Live or by 16 c/o Brian Stolzenbach WNT. Deposition Seyfarth Shaw LLP Video 17 233 S. Wacker Drive Ms. Ellis will testify on the duties and 18 Suite 8000 responsibilities of WNT and MNT Plaintiffs: 1 Chicago, IL 60606 soccer players and the skill required to hour 19 Tel.: (312) 460-5551 complete these duties and 20 responsibilities. She will also testify USSF: 1.50 on USSF’s decision-making as it hours 21 relates to travel, hotel 22 accommodations, and field surfaces This witness for WNT and WNT matches. She will appears in both 23 Plaintiffs’ list also testify on her preference for grass and USSF’s list. 24 field surfaces over artificial turf The times listed surfaces. in Plaintiffs’ list 25 cover the total time expected 26 for the witness’s 27 28

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1 Witness Name/Address Brief Statement of Testimony Time Estimate testimony at 2 trial. 3 Rich Nichols Mr. Nichols is the WNTPA’s former By Deposition 4 c/o Craig Budner Executive Director. In that capacity, Video 5 K&L Gates LLP he helped negotiate the WNTPA’s 1717 Main Street current collective bargaining Plaintiffs: 0.75 6 Dallas, TX 75201 agreement with USSF. hours 7 Tel.: (214) 939-5806 He will testify on the WNTPA’s and USSF: 2.50 8 USSF’s respective positions during hours 9 negotiations over the current collective bargaining agreement for the WNT. This witness 10 appears in both Plaintiffs’ list 11 and USSF’s list. The times listed 12 in Plaintiffs’ list cover the total 13 time expected for the 14 witness’s testimony at 15 trial.

16 17 18 19

20 John Langel Mr. Langel was the WNTPA’s By Deposition 21 c/o William Slaughter Executive Director before Mr. Nichols Video Ballard Spahr LLP held that position. In that capacity, he 22 1735 Market Street negotiated the WNTPA’s prior Plaintiffs: 1.25 23 Philadelphia, PA 19103 collective bargaining agreements with hours Tel.: (215) 864-8114 USSF. 24 USSF: 2.50 25 He will testify on the WNTPA’s and hours USSF’s respective positions during 26 negotiations over prior collective This witness 27 bargaining agreements for the WNT, appears in both including the WNTPA’s requests for Plaintiffs’ list 28 and USSF’s list.

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1 Witness Name/Address Brief Statement of Testimony Time Estimate equal pay. He will also testify about The times listed 2 in Plaintiffs’ list his correspondence with the United cover the total 3 States Olympic Committee concerning time expected USSF’s discriminatory treatment of for the 4 witness’s WNT players. testimony at 5 trial. 6 The Coca-Cola Mr. Seiler is employed as the Director By Deposition 7 Company through of Pro Sports Marketing Portfolio at Video 8 30(b)(6) Designee John the Coca-Cola Company (“Coca- Seiler Cola”). Plaintiffs: 1 9 c/o David Carpenter hour 10 Alston & Bird He will testify on Coca-Cola’s 1201 West Peachtree St. sponsorship agreements with USSF USSF: 0.25 11 Atlanta, GA 30309 and/or Soccer United Marketing, hours 12 Tel.: (404) 881-7881 Coca-Cola’s commitment to the WNT, the popularity of the WNT in the eyes 13 of Coca-Cola, and the drive to sponsor 14 the USSF because of the WNT. Mr. Seiler will also testify on Coca-Cola’s 15 efforts to ensure equal pay for the 16 WNT players and its negotiations with USSF on that issue. 17 18 Visa U.S.A., Inc. Ms. Fisher will testify on Visa U.S.A., By Deposition through 30(b)(6) Inc.’s (“Visa”) sponsorship Video 19 Designee Ashley Fisher agreements with USSF and/or Soccer 20 c/o Andrew Tulumello United Marketing. She will also testify Plaintiffs: 0.75 Gibson, Dunn & on Visa’s desire to have its hours 21 Crutcher LLP sponsorship money paid to USSF or 22 1050 Connecticut Soccer United Marketing specifically USSF: 0.25 Avenue N.W. allocated towards providing equal pay hours 23 Washington, DC 20036 to members of the WNT. She will also 24 Tel.: (202) 955-8657 testify on Visa’s efforts to ensure that at least half of Visa’s investments 25 would fund women’s soccer and/or the 26 WNT. 27 28

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1 II. U.S. Soccer’s Witness List 2 This list identifies the witnesses (in alphabetical order) whom U.S. Soccer 3 intends to call, or may call, at trial, exclusive of any witnesses whom may be called 4 for rebuttal or impeachment. U.S. Soccer reserves the right to call any witness on 5 Plaintiffs’ witness list, if those witnesses are not in fact called by Plaintiffs. U.S. 6 Soccer expressly reserves the right to supplement this list at any time before trial for 7 any reason, and the right to object to any supplemental witnesses identified by 8 Plaintiffs. U.S. Soccer further reserves the right to call or refrain from calling any of 9 the witnesses on this list. 10 Plaintiffs note that there is a pending motion in limine (Dkt. No. 211) seeking to 11 exclude four of U.S. Soccer’s witnesses (Ross Moses, Paul Marstaller, Amy 12 Hopfinger, and Lisa Levine) for the reasons stated in Plaintiffs’ motion in limine No. 13 7. 14

15 Witness Name/Address3 Brief Statement of Testimony Time 16 Estimate 17 Bradley, Kay* Ms. Bradley is the Brand Director for Live U.S. Soccer USSF. She would testify about 18 1801 S. Prairie Avenue, USSF’s marketing, advertising, and USSF: 1.50 Chicago, IL 60616 promotion of the USWNT and hours 19 (312) 808-1300 USMNT. Plaintiffs: 1 20 hour 21 22 23 24 25 26 27 3 Pursuant to Local Rule 16-5 the “*” denotes witnesses “whom [U.S. Soccer] may call 28 only if the need arises.”

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1 Witness Name/Address3 Brief Statement of Testimony Time 2 Estimate 3 4 Ellis, Jill* Ms. Ellis is the former Head Coach of Live or Video U.S. Soccer the USWNT. She would testify about Deposition 5 1801 S. Prairie Avenue, the quality and nature of the coaching, Chicago, IL 60616 technical, and medical staff, hotel This witness 6 (312) 808-1300 accommodations, field surfaces, and appears in air travel for the USWNT during her both 7 tenure, as well as the generally high Plaintiffs’ list level of support for the WNT from and USSF’s 8 USSF during her tenure. list. The times listed in 9 Plaintiffs’ list cover the total 10 time expected for the 11 witness’s testimony at 12 trial. 13 Gulati, Sunil Mr. Gulati is the former President of Live 14 USSF, a member of its Board of Directors until March 2020, a member This witness 15 of the FIFA Council, and otherwise a appears in person who has been involved at the both 16 highest levels of USSF, FIFA, and Plaintiffs’ list Concacaf for many years. He would and USSF’s 17 testify about: the identity, structure, list. The times mission, and history of USSF; the listed in 18 international soccer landscape; the Plaintiffs’ list history of the USWNT, USMNT, and cover the total 19 the various tournaments they play in; time expected the structure, operations, and rules and for the 20 regulations of FIFA and Concacaf; the witness’s parties’ conduct during collective testimony at 21 bargaining negotiations in 2012-2013 trial. (during which Mr. Gulati led the 22 negotiations on USSF’s behalf); the parties’ conduct during some 23 collective bargaining sessions in 2016- 2017 (when Mr. Gulati was personally 24 present); the basis for USSF’s bargaining positions in both sets of 25 negotiations; USSF’s support of the NWSL; history of women’s 26 professional soccer in the United States; and USSF’s financial and other 27 support for the USWNT. 28

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1 Witness Name/Address3 Brief Statement of Testimony Time 2 Estimate 3 4 5 Hopfinger, Amy U.S. Ms. Hopfinger is the Director of Live Soccer Events for USSF. She would testify 6 1801 S. Prairie Avenue, about the venue selection process for USSF: 1.50 Chicago, IL 60616 some USWNT and USMNT matches hours 7 (312) 808-1300 (different matches than those covered by Mr. Marstaller, identified below). Plaintiffs: 1 8 hour 9 Irwin, Carlyn Ms. Irwin is a retained expert and a Live 10 Cornerstone Research forensic accountant. She would testify 555 W. 5th street, 38th to her calculation of MNT and WNT USSF: 3.0 11 Floor player compensation and USSF game- hours Los Angeles, CA 90013 related revenue during various 12 (213) 553-2533 periods, based on her review of USSF Plaintiffs: 1 business records (see content of her hour 13 reports for further details). 14 King, Tom Mr. King is the Managing Director of Live U.S. Soccer National Teams and has served in a 15 1801 S. Prairie Avenue, similar role for USSF since the 1990s. This witness Chicago, IL 60616 He would testify about the parties’ appears in 16 (312) 808-1300 conduct during collective bargaining both negotiations in 2015-2017 (during Plaintiffs’ list 17 which he served as official notetaker and USSF’s for USSF and was present for all but list. The times 18 one session); the basis for some of listed in USSF’s proposals; the operational Plaintiffs’ list 19 distinctness of the USMNT and cover the total USWNT; the nature and structure of time expected 20 the tournaments the USWNT and for the USMNT play in; the U-23 MNT and witness’s 21 its compensation (or lack thereof) for testimony at playing in the Olympics and Olympic trial. 22 qualifiers; actual compensation paid to the USMNT and USWNT; content 23 and administration of CBAs for both teams; air travel, hotel 24 accommodations, and staff of the two teams; and prize money available 25 from FIFA, Concacaf, and CONMEBOL for different 26 tournaments. 27 28

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1 Witness Name/Address3 Brief Statement of Testimony Time 2 Estimate 3 4 5 Klingenberg, Meghan Plaintiff Klingenberg was one of three Video Plaintiff Player Representatives in charge of Deposition 6 the WNTPA when it negotiated the current CBA, alleged by Plaintiffs to USSF: 0.75 7 be discriminatory. Her videotaped hours testimony includes her own 8 admissions against interest, testimony Plaintiffs: 0.5 related to the fact that she was paid hours 9 more under the 2017 WNT CBA than she would have been paid under the 10 MNT CBA in effect during the same time; testimony about payments made 11 by the WNTPA to players; and testimony about the conduct of 12 negotiations from the perspective of a Player Representative. 13 14 Langel, John Mr. Langel is a retired labor lawyer Video who served as the WNTPA’s Deposition 15 Executive Director and General Counsel from its formation through This witness 16 2014. He was the chief spokesperson appears in for the WNTPA during the 2012-2013 both 17 negotiations, which culminated in the Plaintiffs’ list 2013-2016 CBA. His videotaped and USSF’s 18 testimony authenticates documents list. The times related to the 2012-2013 CBA listed in 19 negotiations and includes testimony Plaintiffs’ list about those negotiations that supports cover the total 20 USSF’s legal position, coming from time expected the perspective of Plaintiffs’ for the 21 representative during those witness’s negotiations. testimony at 22 trial. 23 Levine, Lisa* Ms. Levine is the former General Live Counsel of USSF. She would testify 24 about the conduct of the parties during USSF: 1.50 collective bargaining negotiations in hours 25 2012-2013 (when she served as official notetaker) and the conduct of Plaintiffs: 1 26 the parties during collective hour bargaining negotiations in 2015-2017, 27 28

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1 Witness Name/Address3 Brief Statement of Testimony Time 2 Estimate 3 including a session at which neither Mr. Gulati nor Mr. King was present. 4 5 Marstaller, Paul Mr. Marstaller is the Director of Event Live 6 U.S. Soccer Revenue for USSF. He would testify 1801 S. Prairie Avenue, about the venue selection process for USSF: 1.50 7 Chicago, IL 60616 some USWNT and USMNT matches hours (312) 808-1300 (different matches than those covered 8 by Ms. Hopfinger, identified above). Plaintiffs: 1 hour 9 10 McCrary, Justin Mr. McCrary retained expert and a Live Columbia University labor economist. He would testify 11 School of Law about his analysis of the USMNT and USSF: 3.0 521 Jerome Greene Hall USWNT CBAs and the compensation hours 12 New York, NY 10027 of the two teams and certain individual (510) 409-6418 players (see his reports for further Plaintiffs: 2 13 detail). hours 14 Miscimarra, Philip Mr. Miscimarra is a retained expert in Live Partner the field of labor relations. He would 15 Morgan, Lewis & explain to the jury how collective USSF: 2.0 Bockius LLP bargaining works and whether the hours 16 1111 Pennsylvania WNTPA’s and USSF’s conduct in Avenue, NW, negotiations was unusual in light of Plaintiffs: 1 17 Washington, DC 20004 the rules regulating collective hour (202) 739-5565 bargaining and the ordinary practice of 18 unions and employers in collective bargaining (see his report(s) for 19 further detail). 20 Morgan, Alex Ms. Morgan is a Plaintiff and Title VII Live or 21 Class Representative. Her testimony Deposition includes her own admissions against Designation 22 interest, including but not limited to testimony related to the collective This witness 23 bargaining process from the appears in perspective of a plaintiff, class both 24 representative, and member of the Plaintiffs’ list WNTPA collective bargaining and USSF’s 25 committee. list. The times listed in 26 Plaintiffs’ list cover the total 27 time expected for the 28 witness’s

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1 Witness Name/Address3 Brief Statement of Testimony Time 2 Estimate 3 testimony at trial. 4 5 6 Moses, Ross Mr. Moses is Director of Analytics Live U.S. Soccer and Research for USSF. He would 7 1801 S. Prairie Avenue, testify about television ratings and USSF: 1.25 Chicago, IL 60616 attendance for USMNT and USWNT hours 8 (312) 808-1300 matches, including specifically the explanation and authentication of Plaintiffs: 1 9 business records regarding the same. hour 10 Nichols, Rich Mr. Nichols is a lawyer who served as Video 11 Former Executive the WNTPA’s Executive Director and Deposition Director of the WNTPA General Counsel from late 2014 12 through late 2016. He was the chief This witness spokesperson for the WNTPA during appears in 13 the 2015-2016 negotiations, which both sought to achieve a successor to the Plaintiffs’ list 14 2013-2016 CBA. His videotaped and USSF’s testimony authenticates documents list. The times 15 related to the 2015-2016 CBA listed in negotiations and includes testimony Plaintiffs’ list 16 about those negotiations that supports cover the total USSF’s legal position, coming from time expected 17 the perspective of Plaintiffs’ for the representative during those witness’s 18 negotiations. His testimony also testimony at authenticates documents and provides trial. 19 facts related to side agreements between the WNTPA and USSF 20 concerning player compensation, provides context for the WNTPA’s 21 and Plaintiffs’ actions in negotiations and this lawsuit, and authenticates 22 documents and provides facts related to payments by USSF to the WNTPA 23 and the distribution of some of those funds to Plaintiffs. 24 25 26 27 28

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1 Witness Name/Address3 Brief Statement of Testimony Time 2 Estimate 3 4 5 6 O’Hara, Kelley Plaintiff O’Hara is one of three current Deposition Plaintiff Player Representatives in charge of Designation 7 the WNTPA, and she participated in the negotiations for the current CBA, USSF: 1.25 8 alleged by Plaintiffs to be hours discriminatory. Her testimony includes 9 admissions against interest, testimony Plaintiffs: 0.5 related to the fact that she was paid hours 10 more during certain periods of time under the WNT CBA than she would 11 have been paid under the MNT CBA in effect during the same time; and 12 testimony about the conduct of negotiations from the perspective of a 13 direct participant and member of the WNTPA’s collective bargaining 14 committee. 15 Press, Christen Plaintiff Press was one of three Player Live or 16 Plaintiff Representatives in charge of the Deposition WNTPA when it negotiated the Designation 17 current CBA, alleged by Plaintiffs to be discriminatory. Her testimony This witness 18 includes her own admissions against appears in interest and testimony about the both 19 conduct of negotiations from the Plaintiffs’ list perspective of a Player Representative. and USSF’s 20 list. The times listed in 21 Plaintiffs’ list cover the total 22 time expected for the 23 witness’s testimony at 24 trial. 25 Raina, Praptika (Pinky) Ms. Raina is USSF’s Chief Financial Live Chief Financial Officer Officer. She would testify about 26 U.S. Soccer revenue received as a result of the This witness 1801 S. Prairie Avenue, activities of the USWNT and USMNT appears in 27 and monies paid to same and their both unions, including (if necessary) Plaintiffs’ list 28

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1 Witness Name/Address3 Brief Statement of Testimony Time 2 Estimate 3 Chicago, IL 60616 authentication of business records and USSF’s (312) 808-1300 reflecting the same. list. The times 4 listed in Plaintiffs’ list 5 cover the total time expected 6 for the witness’s 7 testimony at trial. 8 Roux, Rebecca Ms. Roux has served as the WNTPA’s Live or Video 9 Executive Director Executive Director since early 2017. Deposition4 WNTPA She was one of the WNTPA’s 10 representatives during the 2017 USSF: 1.0 negotiations that culminated in the hour 11 current WNT CBA, whose term runs from 2017 through 2021, and she Plaintiffs: 1 12 continues to be responsible for hour administering that CBA. She will 13 testify documents related to the 2017 CBA negotiations and will give 14 testimony about the conduct of those negotiations that supports USSF’s 15 legal position, coming from the perspective of Plaintiffs’ 16 representative during those negotiations. Her testimony also will 17 include testimony about a calculation Plaintiffs submitted to the Court to 18 demonstrate how they would be paid under the USMNT CBA, which 19 calculation differs materially from the calculation performed by Finnie Cook 20 for the same purpose, the latter of which Plaintiffs now purport to submit 21 to the Court for the same purpose. Her testimony also will authenticate 22 documents and provides facts related to side agreements between the 23 WNTPA and USSF concerning player compensation, payments by USSF to 24 the WNTPA, payments to the WNTPA as a result of a licensing 25

26 4 USSF has designated Ms. Roux’s deposition testimony, but it anticipates 27 subpoenaing her to testify live and anticipates that Ms. Roux will comply with the subpoena. If USSF is required to play videotape of Ms. Roux’s deposition testimony, 28 it has designated approximately two hours of testimony.

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1 Witness Name/Address3 Brief Statement of Testimony Time 2 Estimate 3 agreement, and distribution of WNTPA funds to Plaintiffs. 4 5 6 7 8 Sauer, Russ* Mr. Sauer is a retired lawyer who Live 9 represented USSF during the 2015- 2017 CBA negotiations. He would USSF: 1.5 10 testify about the conduct of the hours WNTPA’s and USSF’s representatives 11 during those negotiations, and this Plaintiffs: 1 would include testimony regarding hour 12 one or more conversations with WNTPA representatives during which 13 no other USSF representative was present. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 Dated: March 31, 2020 WINSTON & STRAWN LLP 2 By: /s/ Jeffrey L. Kessler5 Jeffrey L. Kessler 3 David G. Feher Cardelle B. Spangler 4 Diana Hughes Leiden Jeanifer E. Parsigian 5 Lev Tsukerman 6 Diana Hughes Leiden (SBN: 267606) [email protected] 7 Lev Tsukerman (SBN: 319184) [email protected] 8 333 South Grand Avenue, 38th Floor Los Angeles, CA 90071-1543 9 Telephone: (213) 615-1700 Facsimile: (213) 615-1750 10 Jeanifer E. Parsigian (SBN: 289001) 11 [email protected] 101 California St., 35th Floor 12 San Francisco, California 94111 Telephone: (415) 591-1000 13 Facsimile: (415) 591-1400 14 Attorneys for Plaintiffs 15 Dated: March 31, 2020 LATHAM & WATKINS LLP 16 By: /s/ Jamie L. Wine 17 Jamie L. Wine Michele D. Johnson 18 SEYFARTH SHAW LLP 19 By: /s/ Giovanna A. Ferrari 20 Giovanna A. Ferrari 21 Ellen E. McLaughlin (Admitted Pro Hac Vice) 22 E-mail: [email protected] Noah Finkel (Admitted Pro Hac Vice) 23 E-mail: [email protected] Brian Stolzenbach (Admitted Pro Hac 24 Vice) E-mail: [email protected] 25 Sharilee Smentek (Admitted Pro Hac Vice) E-mail: [email protected] 26 Cheryl A. Luce (Admitted Pro Hac Vice) 27 5 I, Jeffrey L. Kessler, attest that all other signatories listed, and on whose behalf this 28 filing is submitted, concur in the filing’s content and have authorized the filing.

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1 E-mail: [email protected] 233 South Wacker Drive, Suite 8000 2 Chicago, Illinois 60606-6448 Telephone: (312) 460-5000 3 Facsimile: (312) 460-7000 4 Kristen M. Peters (SBN 252296) E-mail: [email protected] 5 2029 Century Park East, Suite 3500 Los Angeles, California 90067-3021 6 Telephone: (310) 277-7200 Facsimile: (310) 201-5219 7 Giovanna A. Ferrari (SBN 229871) 8 [email protected] Chantelle C. Egan (SBN 257938) 9 [email protected] 560 Mission Street, 31st Floor 10 San Francisco, California 94105 Telephone: (415) 397-2823 11 Facsimile: (415) 397-8549 12 Kyllan Kershaw (Admitted Pro Hac Vice) [email protected] 13 1075 Peachtree Street, NE, Suite 2500 Atlanta, GA 30309 14 Telephone: (404) 885-1500 Facsimile: (404) 892-7056 15 16 Attorneys for UNITED STATES SOCCER FEDERATION, INC. 17 18 19 20 21 22 23 24 25 26 27 28

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