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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HOMEADVISOR, INC., a corporation, 

d/b/a ANGI LEADS, 

d/b/a HOMEADVISOR POWERED BY ANGI. DOCKET NO. 9407 

COMPLAINT COUNSEL’S OPPOSITION TO 

RESPONDENT HOMEADVISOR, INC.’S MOTION TO RE-OPEN AND 

COMPEL DEPOSITION TESTIMONY OF AMY BRANNON-QUALE 

Respondent’s Motion demands an “unobstructed deposition” of a member of Complaint 

Counsel’s legal team, investigator Amy Brannon-Quale, regarding her recollections and 

impressions of Complaint Counsel’s communications with third-party declarants. Such an 

unfettered, extraordinary, and dangerous request runs contrary to decades of work product 

precedent and seeks to turn the doctrine on its head. To be clear, Respondent seeks protected 

core opinion work product, which is “generally afforded near absolute protection” and is 

“discoverable only upon a showing of rare and exceptional circumstances.” In re Cendant Corp. 

Sec. Litig., 343 F.3d 658, 663 (3d Cir. 2003). 

Respondent’s Motion does not dispute that its “unobstructed” request would necessarily 

invade Complaint Counsel’s work product. Instead, Respondent wrongly posits Complaint 

Counsel has waived its work product protections, or in the alternative, Respondent has a 

“substantial need” for it. Neither is true, and Respondent’s Motion should be denied in its 

entirety. 

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BACKGROUND 

On April 7, 2022, Complaint Counsel filed a summary decision motion attaching 

voluminous documents, including declarations obtained from eighteen consumers and former 

employees of HomeAdvisor. See RX2. Complaint Counsel produced its written communications 

with those third parties. Decl. of Sophia Calderón (“Calderón Decl.”) at ¶¶ 4-5. 

Complaint Counsel also submitted a declaration from Amy Brannon-Quale, an FTC 

investigator, authenticating web captures and attaching BBB complaints. See RX1. As a member 

of Complaint Counsel’s legal team, Ms. Brannon-Quale’s investigative activities in this case 

have been performed at the direction of Complaint Counsel in anticipation of litigation. See 

Calderón Decl. at ¶ 3. 

On May 19, 2022, Respondent deposed Ms. Brannon-Quale. RX30. Respondent 

primarily attempted to examine her on her memory of third-party witnesses with whom she has 

interacted, the substance of communications with third parties (including non-declarants), and 

documents she has reviewed or drafted in her investigative work. See RX30 at 16:18-32:4. 

Complaint Counsel asserted work product objections to this line of questioning. Id. Respondent’s 

sole questions relating to Ms. Brannon-Quale’s declaration queried why she included BBB 

complaints in her declaration, RX30 at 12:3-13:5, and her awareness and review of additional 

BBB complaints not attached to her declaration, id. at 13:21-14:15. 

ARGUMENT 

1. Ms. Brannon-Quale’s Recollections Are Core Opinion Work Product 

The attorney work product doctrine limits discovery of materials prepared in anticipation 

of litigation. 16 C.F.R. § 3.31(c)(5); In the Matter of Lab. Corp. of Am. & Lab. Corp. of Am. 

Holdings, No. 9345, 2011 WL 822928, at *3 (F.T.C. Feb. 24, 2011). Work product protection 

extends to intangible work product and beyond attorneys to investigators working under attorney 

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direction and supervision. United States v. Nobles, 422 U.S. 225, 238-39 (1975); Hickman v. 

Taylor, 329 U.S. 495, 510-11 (1947) (protection extends to intangible work product, such as 

attorney’s recollection of what witness told him); Cendant Corp., 343 F.3d at 662. 

Federal courts have developed a two-tiered analysis for determining when information is 

protected by the work product doctrine. See Cendant Corp., 343 F.3d at 663; Baker v. General 

Motors Corp., 209 F.3d 1051, 1054 (8th Cir. 2000). First, core opinion work product, which 

encompasses the “mental impressions, conclusions, opinion, or legal theories of an attorney or 

other representative of a party concerning the litigation, is generally afforded near absolute 

protection from discovery” and is “discoverable only upon a showing of rare and exceptional 

circumstances.” Cendant Corp., 343 F.3d at 663; see also Baker, 209 F.3d at 1054. Second, 

ordinary/factual work product, which is limited to factual information, is discoverable only if the 

party seeking the information has a substantial need for the information and cannot without 

undue hardship obtain its substantial equivalent by other means. Baker, 209 F.3d at 1054; 16 

C.F.R. § 3.31(c)(5). 

While ignoring this two-tiered analysis, Respondent briefly claims that it seeks only 

factual work product, characterizing its request as seeking “the acts taken by FTC staff and third 

parties’ statements to FTC staff.” Motion at 7. But to the contrary, Respondent seeks to force 

Complaint Counsel’s investigator to testify (by recollection) regarding the substance of her 

witness interviews and interactions. Federal courts are clear that such a request unavoidably 

invades the core opinion work product, which is entitled to near absolute immunity. See In re 

Sealed Case, 856 F.2d 268, 273 (D.C. Cir. 1988) (SEC attorneys’ recollections of witness 

interviews were attorney work product and because the “work product sought here is based on 

oral statements from witnesses, a far stronger showing is required than the ‘substantial need’” 

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standard); Shelton v. Am. Motors Corp., 805 F.2d 1323, 1328-29 (8th Cir. 1986) (attorney’s 

recollection would indicate that “since it was important enough to remember, she must be relying 

on it in preparing her client’s case”); In re Grand Jury Proceedings, 473 F.2d 840, 848 (8th Cir. 

1973) (attorney’s personal recollections pertaining to witness interviews are “absolutely” 

protected work product). Indeed, an “unobstructed deposition” of Ms. Brannon-Quale’s 

recollection of her interviews and interactions with third-party witnesses would “inevitably 

invade” her mental impressions and Complaint Counsel’s core opinion work product. S.E.C. v. 

Johnson, No. CV 05-36 (GK), 2007 WL 9702653, at *2 (D.D.C. Aug. 22, 2007) (testimony 

regarding an attorney’s role “in shaping and developing the nature of statements and testimony 

provided by witnesses” would “inevitably invade[]” attorney thoughts, perceptions, strategy and 

conclusions). 

2. Complaint Counsel Has Not Waived Work Product Protection 

Respondent argues that, because Complaint Counsel has produced its written 

communications with third-party declarants and did not object when Respondent’s counsel was 

deposing those declarants, Complaint Counsel has waived its work product protections of 

Ms. Brannon-Quale’s recollections of those communications. This argument fails. 

Complaint Counsel’s use of third-party declarants as witnesses—or mere production of 

written communications with those same witnesses—does not constitute a waiver of 

Ms. Brannon-Quale’s mental impressions regarding those witnesses. Indeed, work product 

waiver generally applies only to the specific materials disclosed and not to the broader subject 

matter of the information. 16 C.F.R. § 3.31(g)(2); Fed. R. Evid. 502(a) (Advisory Committee 

Notes); see also Trs. Of Elec. Workers Local No. 26 Pension Tr. Fund v. Tr. Fund Advisors, Inc., 

266 F.R.D. 1, 11 (D.D.C. 2010) (Rule 502(a) “abolishe[d] the dreaded subject-matter waiver, 

i.e., that any disclosure of privileged matter worked a forfeiture of any other privileged 

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information that pertains to the same subject matter.”). The “subject matter waiver” that 

Respondent seeks is strictly “limited to situations in which a party intentionally puts protected 

material information into the litigation in a selective, misleading and unfair manner.” Fed. R. 

Evid. 502(a) (Advisory Committee Notes). Further, “work-product waiver only extends to 

‘factual’ or non-opinion’ work product concerning the same subject matter as the disclosed work 

product.” Cave Consulting Group, Inc. v. OptumInsight, Inc., No. 15-CV-03424-JCS, 2017 WL 

5078436, at *3 (N.D. Cal. Nov. 6, 2017) (quoting In re EchoStar Commc’ns Corp., 448 F.3d 

1294, 1302 (Fed. Cir. 2006)). 

Respondent’s request is wholly incompatible with this standard. To be clear, Complaint 

Counsel has not been selective, misleading, or unfair in producing its written communications 

with third-party declarants—and Respondent knows this.1

 Nor has Complaint Counsel made 

testimonial use of Ms. Brannon-Quale’s recollections and mental impressions stemming from her 

interviews and interactions with the third-party declarants, and thus has not waived this work 

product.2 O’Connor v. Boeing N. Am., Inc., 216 F.R.D. 640, 644 (C.D. Cal. 2003); see also Nobles, 

422 U.S. at 239-40 (finding testimonial use of work product materials occurred when party “sought 

1 Respondent’s accusation that Complaint Counsel selectively withheld third-party communications, Motion at 6, is 

demonstrably false. Complaint Counsel has produced all written communications with the third-party declarants, 

withholding only its own internal notes, summaries, drafts, and memoranda regarding its interactions with these 

witnesses. Calderón Decl., ¶¶ 4-5. Indeed, Complaint Counsel inadvertently produced one internal draft declaration 

containing attorney notes, and upon discovering the inadvertent production promptly notified Respondent. Id. ¶ 7, 

PX01 (April 25, 2022 notice letter). Respondent never disputed Complaint Counsel’s claim of work product on this 

document, nor did it “promptly” present it for determination of the work product claim pursuant to 

Rule 3.31(g)(1)(ii), Calderón Decl., ¶ 8, and therefore cannot dispute the work product claim now. Incredibly, 

despite its obligation under Rule 3.31(g)(1)(ii) to “promptly return, sequester, or destroy” the document and its 

prohibition to not “use or disclose” the document, Respondent attached the work product document in support of 

its Motion. See RX12. 

2 Tellingly, Respondent’s Motion does not cite Ms. Brannon Quale’s declaration to support its waiver arguments. 

Submission of a declaration about ministerial tasks by a member of a party’s legal team does not open that 

individual to deposition about protected matters beyond the scope of the tasks described. In re Traffic Jam Events 

LLC, No. 9395, 2021 WL 3465724, at *3-4 (F.T.C. July 23, 2021). 

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to adduce the testimony of [his attorney’s] investigator and contrast [the investigator’s] recollection 

of the contested statements with that of the prosecution’s witnesses”). 

To manufacture a waiver argument, Respondent attempts to frame the work product at 

issue broadly as “the FTC’s third-party interactions.” Motion at 6. But Respondent cites no 

support for its position that Complaint Counsel’s lack of objections to third-party testimony 

regarding communications with Ms. Brannon-Quale or its production of written communications 

with third parties3 should result in an unobstructed deposition of Ms. Brannon-Quale’s 

recollection and mental impressions. It is the questioning of Ms. Brannon-Quale—not of the 

third-party declarants—that implicates work product here. Indeed, one of Respondent’s cited 

cases, S.E.C. v. Gupta, confirms that Complaint Counsel would have had no basis to object to 

questioning of third-party declarants about the witnesses’ own recollections. 281 F.R.D. 169, 

171 (S.D.N.Y. 2012) (holding SEC lawyer could not assert work product protections to block a 

third-party witness from being questioned about the witness’ own recollections of meeting with 

SEC counsel). But allowing third parties to testify about conversations with Ms. Brannon-Quale 

does not subject her to questioning.4

 No waiver of Ms. Brannon-Quale’s recollections has 

occurred. 

3. Respondent Has Not Shown “Rare And Exceptional Circumstances” or “Substantial 

Need” 

Under Rule 3.31(c)(5), a party may obtain discovery of certain work product only upon a 

showing of “substantial need.” Respondent mistakenly relies on this provision, but federal courts 

3 The communications produced are: (a) emails scheduling telephone conversations; (b) Complaint Counsel’s 

transmittal of declarations to the third parties for signature; (c) declarants forwarding HomeAdvisor communications 

to Complaint Counsel; and (d) declarants providing information to Complaint Counsel. See RX3-RX15. 

4 Respondent’s argument would undermine the purposes of discovery and encourage over-withholding by parties. 

Cf. Duplan Corp. v. Deering Milliken, Inc., 540 F.2d 1215, 1222 (4th Cir. 1976) (“The net effect of such rule would 

result in great reluctance to produce any work product documents for fear that it might waive the immunity as to all 

similar documents.”). 

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are clear that the “substantial need” standard applies to ordinary/factual work product. See 

Baker, 209 F.3d at 1054; Cendant Corp., 343 F.3d at 663. A party’s core opinion work product, 

which is what is at issue here, see infra, Section 1, “is discoverable only upon a showing of rare 

and exceptional circumstances.” Cendant Corp., 343 F.3d at 663; see also Baker, 209 F.3d 

at 1054. Forcing Complaint Counsel’s investigator to testify regarding the substance of her 

witness interviews unavoidably invades Complaint Counsel’s core opinion work product, and 

Respondent’s desire to hear more about Complaint Counsel’s interactions with third-party 

witnesses does not amount to “rare and exceptional circumstances.” See In re Sealed Case, 856 

F.2d at 273; In re Grand Jury Proceedings, 473 F.2d at 848-49; Shelton, 805 F.2d at 1328-29. 

Respondent has not even addressed this higher standard for core opinion work product, and for 

this reason alone its argument fails. 

Moreover, even if what Respondent seeks was mere ordinary/fact work product—which 

it is not—Respondent has not established a “substantial need” for Ms. Brannon-Quale to testify 

regarding her recollections of witness interactions. Of course, “there is in general no justification 

for discovery of the statement of a person contained in work product materials when the person 

is available to be deposed.” Gay v. P.K. Lindsay Co., Inc., 666 F.2d 710, 713 (1st Cir. 1981); see 

also Baker, 209 F.3d at 1054. Here, Respondent has already taken testimony from the vast 

majority of third-party declarants. And its “examples” of “limited testimony,” with “remarkable 

lapses in memory,” Motion at 1-3, fail to demonstrate substantial need and grossly misstate 

testimony: 

• That Kelly Hopkins could not recall exact names of Complaint Counsel or 

HomeAdvisor’s sales representative does not illustrate “remarkable lapses in memory,” 

nor is it inconsistent with his recollection of his interaction with HomeAdvisor in his 

declaration—details which Respondent has had an opportunity to explore in deposition. 

See RX2. 

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• Richard Prince testified that, while Ms. Brannon-Quale did the physical act of writing 

Mr. Prince’s statement into the declaration based on their conferences, “she scripted 

everything the way I told her . . . , I think she got it exactly like I told her.” RX18 

at 179:20-25, 180:6-9 (“She didn’t change nothing. What you’re reading here, or 

whatever that thing is, is exactly the way I told her it happened”); compare Motion at 2. 

• Mark Rothermel, despite some initial confusion regarding the signing and returning of 

his declaration, made clear in his deposition that there is no actual dispute that he signed 

and returned his declaration to Complaint Counsel. RX19 at 93:1-5; 99:5-8; 101:1-10; 

compare Motion at 3. 

• Trenton Grimes’ declaration was signed before Ms. Brannon-Quale even worked on this 

case, and therefore she could not possibly offer any testimony regarding its drafting. See 

Motion at 3. 

These examples only prove that Respondent already had the opportunity to challenge the 

deponents’ credibility—and they found nothing. 

Respondent also argues it learned in some of the declarant’s depositions that some sought 

to revise statements in their executed declarations. Motion at 8. In one example, in preparation 

for her deposition, a witness re-reviewed her declaration and asked to delete one word 

(“exclusively”). RX25 at 18:2-19:21. Another transcript cited does not show any attempt to 

change the text of a declaration after execution. RX21 at 15:20-20:20. For the three other 

depositions cited, Respondent’s Motion cites to the entire transcripts without any specific 

examples. Regardless, Respondent was able to fully examine the declarants about their 

declarations, and a party normally cannot show a substantial need for information when “it 

merely seeks corroborative evidence” Baker, 209 F.3d at 1054, or to impeach a witness, 

Clemmons v. Academy for Educ. Dev., 300 F.R.D. 6, 8 (D.D.C. 2013); McPeek v. Ashcroft, 202 

F.R.D. 332, 339 (D.D.C. 2001) (“[I]f the desire to impeach a witness with prior inconsistent 

statements is a sufficient showing of substantial need, the work product privilege would cease to 

exist[.]”). 

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Finally, even if Respondent could establish a basis with respect to one declarant on some 

limited issue, that should not obviate work product with respect to every witness and with 

unobstructed scope. Rather than identifying questions it believes were wrongly blocked, 

HomeAdvisor instead seeks a plainly improper order to completely bar Complaint Counsel from 

asserting protections explicitly protected by the Rules of Practice, 16 C.F.R. § 3.31(c)(5). 

CONCLUSION 

For the foregoing reasons, Respondent’s Motion should be denied. 

Respectfully submitted, 

Dated: August 9, 2022 s/ Sophia H. Calderón 

Sophia H. Calderón 

Colin D. A. MacDonald 

Breena M. Roos 

M. Elizabeth Howe 

Katharine F. Barach 

Nadine S. Samter 

Federal Trade Commission 

Northwest Region 

915 Second Ave., Suite 2896 

Seattle, WA 98174 

Tel.: (206) 220-6350 

Fax: (206) 220-6366 

Email: scalderon@ftc.gov 

cmacdonald@ftc.gov 

broos@ftc.gov 

mhowe@ftc.gov 

Counsel Supporting the Complaint 

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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HOMEADVISOR, INC., a corporation, 

d/b/a ANGI LEADS, 

d/b/a HOMEADVISOR POWERED BY ANGI. DOCKET NO. 9407 

DECLARATION OF SOPHIA H. CALDERÓN 

My name is Sophia H. Calderón, I am over eighteen years of age, and I am a citizen of 

the United States. I have personal knowledge of the information contained herein. If called as a 

witness, I could and would testify as follows: 

1. I am an attorney licensed to practice law in California, am a full time employee of the 

Federal Trade Commission, and am Complaint Counsel in the above-captioned matter. 

2. Since 2019, I have been the lead attorney assigned to the FTC’s investigation of and later 

complaint against HomeAdvisor, Inc. 

3. Amy Brannon-Quale is an investigator in my office and has worked on the investigation 

and litigation regarding HomeAdvisor, Inc. exclusively at my direction and the direction 

of other attorneys. 

4. On April 6, 2022, Complaint Counsel served Respondent with its initial disclosures, 

accompanied by copies of then-existing nonprivileged written communications between 

Complaint Counsel and the third-party declarants in this case. 

5. Since then, Complaint Counsel has supplemented its initial disclosures with additional 

productions of nonprivileged material generated during the litigation. 
 

 

 

 

 

 

 

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6. Except as noted in Paragraph 7, below, Complaint Counsel has not produced to 

Respondent its own notes, summaries, internal draft declarations never sent to third-party 

declarants, or memoranda regarding its communications with third parties. 

7. Complaint Counsel’s April 6, 2022 production inadvertently included a draft declaration 

that contains attorney edits and comments. Promptly after discovering this inadvertent 

production, on April 25, 2022, I sent a letter to Respondent’s Counsel informing them of 

this inadvertent production of a document containing protected attorney work product 

and requesting Respondent to “return, sequester, or destroy all copies” of the document. 

A copy of that letter is attached hereto as PX01. 

8. Respondent never contacted me to challenge the instruction in my April 25 letter. 

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and 

correct. 

Executed on August 9, 2022. s/ Sophia H. Calderón 

Sophia H. Calderón 

Counsel Supporting the Complaint 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 8/9/2022 | Document No. 605273 | PAGE Page 12 of 15 * PUBLIC *; 

PX01 

PUBLIC
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UNITED STATES OF AMERICA 

Federal Trade Commission 

Seattle, Washington 98174 

Sophie Calderón 

 Attorney

 Northwest Region 

 (206) 220-4486 

April 25, 2022 

VIA EMAIL 

HomeAdvisor, Inc. 

c/o Quinn Emanuel Urquhart & Sullivan, LLP 

Attn: William A. Burck 

Stephen R. Neuwirth 

Jennifer J. Barrett 

Dawn Y. Yamane Hewett 

Kyra R. Simon 

Neil T. Phillips 

George T. Phillips 

Jared Ruocco 

williamburck@quinnemanuel.com 

stephenneuwirth@quinnemanuel.com 

jenniferbarrett@quinnemanuel.com 

dawnhewett@quinnemanuel.com 

kyrasimon@quinnemanuel.com 

neilphillips@quinnemanuel.com 

georgephillips@quinnemanuel.com 

jaredruocco@quinnemanuel.com 

Re: In the Matter of HomeAdvisor, Inc., Docket No. 9407 

Notice of Inadvertent Disclosure of Protected Information 

Dear Counsel, 

Pursuant to 16 C.F.R. § 3.31(g)(1), Complaint Counsel hereby provides notice that its April 6, 

2022 document production inadvertently contained a protected document. Specifically, the 

document beginning with the Bates number FTC_HOMEADVISOR0009539 contains attorney 

work product and is therefore protected under § 3.31(c)(5). 

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y 

PUBLIC

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turn, sequester, or destroy all copies of the As required under § 3.31(g)(1)(ii), please promptly re

stions or concerns, please contact me. above-referenced document. If you have any que

Sincerely, 

Digitally signed by SOPHIA

CALDERON SOPHIA CALDERON 

Date: 2022.04.25 17:24:23 -07'00' 

Sophie Calderón 

Cc: Colin D. A. MacDonald (by email) 

Breena M. Roos (by email) 

 Elizabeth Howe (by email) M.
 

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CERTIFICATE OF SERVICE 

I hereby certify that on August 9, 2022, I filed the foregoing document electronically 

using the FTC’s E-Filing system, which will send notification of such filing to: 

April Tabor 

Office of the Secretary 

Federal Trade Commission 

Constitution Center 

400 Seventh Street, SW, Suite 5610 

Washington, D.C. 20024 

ElectronicFilings@ftc.gov 

The Honorable D. Michael Chappell 

Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-110 

Washington, DC 20580 

I further certify that on August 9, 2022, I caused the foregoing document to be served via 

email to: 

William A. Burck 

Dawn Y. Yamane Hewett 

Kyra R. Simon 

Quinn Emanuel Urquhart & Sullivan, LLP 

1300 I Street NW, 9th Floor 

Washington, DC 20005 

(202) 538-8000 

williamburck@quinnemanuel.com 

dawnhewett@quinnemanuel.com 

kyrasimon@quinnemanuel.com 

Counsel for Respondent HomeAdvisor, Inc. 

Stephen R. Neuwirth 

Jennifer J. Barrett 

Neil T. Phillips 

George T. Phillips 

Jared Ruocco 

Kathryn D. Bonacorsi 

Quinn Emanuel Urquhart & Sullivan, LLP 

51 Madison Avenue, 22nd Floor 

New York, NY 10010 

(212) 849-7000 

stephenneuwirth@quinnemanuel.com 

jenniferbarrett@quinnemanuel.com 

neilphillips@quinnemanuel.com 

georgephillips@quinnemanuel.com 

jaredruocco@quinnemanuel.com 

kathrynbonacorsi@quinnemanuel.com 

Dated: August 9, 2022 By: s/ Sophia H. Calderón 

Sophia H. Calderón 

Counsel Supporting the Complaint 

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