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Sarria v. TELUS International (Cda) Inc. — Entry #40: DECLARATION of Audra J

Case: Sarria v. TELUS International (Cda) Inc. nysd · 1:25-cv-00889

filed January 30, 2025

What this document is

Docket entry #40 · filed January 14, 2026

DECLARATION of Audra J. Soloway in Support re: 35 MOTION to Dismiss the Amended Class Action Complaint for Violations of the Federal Securities Laws.. Document filed by Gopi Chande, Vanessa Kanu, Jeffrey Puritt, Michael Ringman, TELUS International (Cda) Inc.. (Attachments: # 1 Exhibit 19 - CIBC Analyst Report).(Soloway, Audra) (Entered: 01/14/2026)

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We follow this case because it names a company we track, although that company is not a party:

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Case 1:25-cv-00889-VM           Document 40     Filed 01/14/26      Page 1 of 2


                          UNITED STATES DISTRICT COURT
                         SOUTHERN DISTRICT OF NEW YORK


JOSÉ LUIS CERÓN SARRIA, Individually
and on Behalf of All Others Similarly Situated,
                                     Plaintiff,

 v.                                                   Case No. 1:25-CV-00889-VM

TELUS INTERNATIONAL (CDA) INC.,
JEFFREY PURITT, VANESSA KANU,
GOPI CHANDE, and MICHAEL RINGMAN,
                                     Defendants.


             DECLARATION OF AUDRA J. SOLOWAY IN SUPPORT
      OF DEFENDANTS’ REPLY IN SUPPORT OF THEIR MOTION TO DISMISS
                THE AMENDED CLASS ACTION COMPLAINT

              AUDRA J. SOLOWAY declares the following pursuant to 28 U.S.C. § 1746:

              1.      I am a member of the law firm Paul, Weiss, Rifkind, Wharton & Garrison

LLP, 1285 Avenue of the Americas, attorneys for defendants TELUS International (CDA) Inc.

d/b/a TELUS Digital (“TI”), Jeffrey Puritt, Vanessa Kanu, Gopi Chande, and Michael Ringman

(together, “Defendants”). I submit this declaration in support of Defendants’ Reply in Support of

their Motion to Dismiss the Amended Class Action Complaint for Violations of the Federal

Securities Laws (the “Complaint”).

              2.      Attached hereto as Exhibit 19 is CIBC’s analyst report, “Banking On A

Stronger Second Half,” published on May 9, 2024, which is cited in the Complaint at paragraph

137. Exhibit 19 is also cited in Plaintiff’s Memorandum of Law in Opposition to Defendants’

Motion to Dismiss at page 26, but was not submitted by Plaintiff with his opposition papers.


       Case 1:25-cv-00889-VM          Document 40       Filed 01/14/26      Page 2 of 2


              I declare under penalty of perjury that the foregoing is true and correct. Executed

on January 14, 2026.

                                                    /s/ Audra J. Soloway
                                                    Audra J. Soloway