Case 2:17-cV-04958-MAK Document 115-12 Filed 09/16/19 Page 1 of 8

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA

)
)
CARD CONNECT, LLC )
)
Plaintiff, )
v. ) Case No. 2:17-cv-04958
)
SHIFT4 PAYMENTS, LLC, et al., )
)
Defendants. )
)

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VIDEOTAPED DEPOSITION OF
BRENDAN GREEN
_______________________________
July 23, 2019
Philadelphia, Pennsylvania
_______________________________

Veritext Legal Solutions
www.veritext.com
215-636-9600

Exhibit 11

ORIGINAL

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BRENDAN GREEN - Dep
Page 15
you're also on LinkedIn, correct?
A. Yes. Okay. So what I'm going to do is I'm
going to walk through just some pages that are publicly
available on LinkedIn. Do you recognize this page?
Yes.
That's you, correct?
Correct.
Okay. And I'm going to mark this as
Exhibit BG-1.
(Exhibit BG-1 was marked for
identification.)
Do you use text messaging, Mr. Green?
Yes.
What type of phone do you have?
An iPhone.
And do you use the iMessage, the Apple
iMessage?
I do.
And do you also use regular texting?
Yes.
I'm going to show you some more
documents, have you take a look at them.
Okay.
I'm going to show you a document

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BRENDAN GREEN - Dep
Page 16
which are text messages, and it is -- actually, I'm
going to mark it first.
(Exhibit BG-2 was marked for
identification.)
(Pause.)
I'm showing you what's been marked as
Exhibit BG-2. It's a document titled March 10, 2017 ,
Text Messages, Bates Numbers 6407 to 6411.
Do you recognize that document?
Yes. That's from my cell phone.
Okay.
Yeah.
And is the number (610) 420-0693, is
that your cell phone number?
A. Yes.
Q. And on here, there's a conversation with
Jared, correct?
Correct.
Mr. Isaacman, correct?
Correct.
And did you have a conversation with
Jared Isaacman on March 10, 2017?
Yes.
How did you communicate with him?

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Case 2:17-cV-04958-MAK Document 115-12 Filed 09/16/19 Page 4 of 8

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BRENDAN GREEN - Dep
Page 17
Via text. Okay. And do you recall what the
substance of this conversation was on March 10th of
2017?
Not exactly word for word or the entire
conversation, no.
Okay. Can you tell me in general terms
your best recollection of what this conversation was
about?
General terms?
Yes.
A discussion.
And what were you and Jared discussing?
(Pause.)
A potential lawsuit with CardConnect.
Do you recall how that came up?
It came up from Jared.
And how did he bring that up?
He brought it up as a concern.
And what did you discuss beyond that?
(Pause.)
A. If there was going to be a lawsuit.
MR. COHEN: Can you read back what he
said, please?
THE VIDEOGRAPHER: "He brought it up
as a concern.

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BRENDAN GREEN - Dep
Page 18
(Continuation of the answer:)
If there was going to be a lawsuit."
(By Mr. Newcomer) And did you discuss
anything else?
At that point, did we discuss -- it was
related to the concern of a lawsuit.
Just so I'm clear, it was the issue of a
potential lawsuit was the only thing that you and
Jared Isaacman discussed that day?
MR. COHEN: Objection; mischaracterizes.
(By Mr. Newcomer) You can answer the
question.
A. The discussion, it was brought up by
Jared that there may be a lawsuit, and the
conversation revolved around that.
Okay. And did you discuss anything else
revolving around that?
The conversation was -- was in regards
to that, yes.
Okay. And what did you and Jared
discuss in regards to that?
That if there was a lawsuit.
Okay. And did you talk about anything
else in regards to if there was a lawsuit, what would
happen?
It was a concern.
Were you working on anything at that time

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BRENDAN GREEN - Dep
Page 19
for Shift4 during March of 2017?
Yes.
What were you working on?
(Pause.)
Onboarding of merchants.
And were you working on anything else?
(Pause.)
A. I don't recall at that moment.
Q. Okay. I'm going to show you another
document.
(Exhibit BG-3 was marked for
identification.)
(By Mr. Newcomer) I'm showing you
what's been marked as Exhibit BG-3. It's entitled,
March 27, 2017, Text Messages, Bates Numbers S4
006422 to S4 006425.
Do you recognize this document?
Yes.
Does this show another exchange with you
and Jared?
Yes.
And this one appears to be on March 27,
2017, correct?
A. Yes.
Q. Do you recall this exchange?
Yes.
Do you -- do you remember this

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BRENDAN GREEN - Dep
Page 20
discussion?
I recall having discussions.
Okay. And do you recall what this
discussion was about?
(Pause.)
It was about a website.
Okay. And can you tell me a little bit
more about this discussion of a website, what
you're -- what was discussed?
That there was a website up, live.
Okay. And who was that -- who was it
that told you that a website was up and live?
(Pause.)
A. Jared and I spoke about it.
Q. Okay. And did he text you to tell you
that a website was up and live?
(Pause.)
Yes.
Okay. And did Jared tell you anything
about the website?
(Pause.)
A. That he believed it was put up by
CardConnect.
Q. Okay. And did he say what was on the
website?
(Pause.)

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BRENDAN GREEN - Dep
Page 21
That it was offensive.
Okay. And after reviewing this
document, does that refresh your recollection about
the conversation you had with Jared about the
website?
MR. COHEN: Objection to the form.
(By Mr. Newcomer) You can answer.
A. Could you repeat that?
Q. Sure. After you've reviewed this
document, Exhibit BG-3 --
Yes.
-- does that refresh your recollection
about the conversation you had with Jared Isaacman
about the website?
Yes.
Okay.
And as a result of having your
recollection refreshed, can you now tell me what the
discussion between you and Jared was on March 27,
2017?
A. That the website was offensive.
Q. Did Jared Isaacman send you the link to
the website?
(Pause.)
A. Yes.
-oOo-

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Case 2:17-cv-04958-MAK Document 115-13 Filed 09/16/19 Page 1 of 5

Exhibit 12
March 10, 2017
Text Messages
Bates Nos. S4 006407-6411

S4006407

Case 2:17-cv-04958-MAK Document 115-13 Filed 09/16/19 Page 2 of 5

Friday, March 10
I think at this point they are
setting up for a lawsuit
8:53 AM

What do you mean?
8:58 AM

They cancelled the Utah trip
for Angelo on the 14th
I was supposed to run trainings
all next week
8:58 AM

Damn man...
9:03 AM

Yup.
I spoke to him the other day to
get it set up.
9:09 AM

Yea that's so fucked.
9:14 AM

Let's start documenting all of
this. Please keep a running log.
9:14 AM

K
9:24 AM

S4006408

Case 2:17-cV-04958-MAK Document 115-13 Filed 09/16/19 Page 3 of 5

Did you receive the link yet for
training on SkyTab?
11:28 AM

No.
11:46 AM

Not sure if it got released yet.
Brian and ray doing it.
11:48 AM

Can we talk Monday about when
and were you think is best to have
them? Think that's a better training
face to face
11:49 AM

Yeah. I'm going to be stuck in
meetings all week but we can
squeeze in some time.
11:55 AM

10-4
11:56 AM

S4006409

Case 2:17-cv-04958-MAK Document 115-13 Filed 09/16/19 Page 4 of 5

Heard from anyone on the inside?
3:03 PM

Nope
3:06 PM

S4006410

Case 2:17-cV-04958-MAK Document 115-13 Filed 09/16/19 Page 5 of 5

Where are we
3:07 PM

They are full of shit and their days
are numbered
I have no interest being collateral
damage
3:07 PM

10-4
3:07 PM

S4006411

Case 2:17-cv-04958-MAK Document 115-14 Filed 09/16/19 Page 1 of 4

Exhibit 13
March 27, 2017
Text Messages
Bates Nos. S4 006422-6425

S4006422

Case 2:17-cv-04958-MAK Document 115-14 Filed 09/16/19 Page 2 of 4

Monday, March 27
Got a little surprise for you on
this beautiful morning
10:07 AM

Oh yea?
10:11 AM

http://www.
thetruthaboutcardconnect.com

10:11 AM

Wow...
10:13 AM

Yea insane right.
10:13 AM

This is nuts.
10:13 AM

I am
10:13 AM

Tell me about. Pretty soon you
will be driving for Uber
10:14 AM

10-4.
10:14 AM

S4006423

Case 2:17-cv-04958-MAK Document 115-14 Filed 09/16/19 Page 3 of 4

I will take screen shots now
10:14 AM

Good idea
10:25 AM

How do u do a screen shot of
the whole site?
10:34 AM

Call mike and see if he can
10:35 AM

K
10:35 AM

Just save the link. I saved it on
the way back machine which is
an Internet archive.
10:36 AM

Cool
10:37 AM

Also, make sure you aren't
logged into Gmail, Facebook,
Instagram and Twitter. All
track ip addresses.
10:38 AM

S4006424

Case 2:17-cv-04958-MAK Document 115-14 Filed 09/16/19 Page 4 of 4

Ok.
10:38 AM

I have a bunch of aliases to use
so I am good. I was using
expble.com too
10:39 AM

You can see screen shots.
10:39 AM

Can you send them to me please?
10:42 AM

Yea I am pulling them up on
another computer
10:43 AM

Thanks.
10:44 AM

I will have em shortly.
10:59 AM

👍
11:00 AM

S4006425

Case 2:17-cv-04958-MAK Document 115-15 Filed 09/16/19 Page 1 of 5

Exhibit 14
March 27, 2017
Text Messages
Bates Nos. S4 006426-6429,
S4 006431

S4006426

Case 2:17-cv-04958-MAK Document 115-15 Filed 09/16/19 Page 2 of 5
Monday, March 27
I just got a text from an ISO
asking if all is good here

11:22 AM

Wow

11:22 AM

It's gonna spread now
11:23 AM

Yup. Like wild fire
11:23 AM

Are you seeing the agent site
too?

11:24 AM

Didn't know there were 2.

11:24 AM
No what's the link to that one?

11:24 AM

S4006427

Case 2:17-cv-04958-MAK Document 115-15 Filed 09/16/19 Page 3 of 5

http://www.
cardconnectexposed.com
11:24 AM

Wow. This is bad
11:25 AM

Yep
11:25 AM

Who is this?
11:26 AM

Whoever it is, it Fucking genius
11:26 AM

Agreed.
11:26 AM

I can tell you for sure it's not
LFG cause they don't even know
some of this shit

11:27 AM

They are not that good
11:28AM

S4006428

Case 2:17-cv-04958-MAK Document 115-15 Filed 09/16/19 Page 4 of 5

If I find out who did this they will
get employee of the month.

11:28 AM

K
11:28 AM
Lol

11:32 AM

We need to scrub our LinkedIn
and all social media. I have done
it so should be good and
recommend you do the same.
11:32 AM

Will do

11:32 AM

I also wouldn't access either of
those sites.
11:33 AM

10-4
11:33 AM

S4006429

Case 2:17-cv-04958-MAK Document 115-15 Filed 09/16/19 Page 5 of 5

I wonder if this will help us get
bought or force a sale
12:22 PM

S4 006431