UNITED STA TES DISTRICT COURT 

EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

w ARNER RECORDS, INC., et al., 

Plaintiffs, 

V. 

AL TICE USA, INC., et al., 

Defendants. 

Case No. 2:23-cv-00576-JRG-RSP 

DECLARATION OF PATRICIA WHEELER 

I. I, Patricia Wheeler, am currently employed at Altice USA, Inc. ("Altice USA") in 

Long Island City, New York, as the Vice President, Legal - Employment, Labor, and Benefits. I 

have been employed by Altice USA since March 2018. J provide this declaration in support of 

Defendants' motion to transfer this case from the Eastern District of Texas to the Eastern District 

of New York. 1 have personal knowledge of the facts set forth herein, except where noted, and, if 

called to testify, could and would competently testify thereto. 

2. As the Vice President, Legal - Employment, Labor, and Benefits, I have personal 

knowledge about the corporate structure, operations, and litigation of Altice USA and its wholly 

owned subsidiary CSC Holdings ("CSC Holdings" and, collectively with Altice USA, "Altice"). 

3. Altice USA is a Delaware corporation with its principal place of business at I Ct. 

Square W, Long Island City, NY 111 01. 

4. CSC Holdings is a Delaware limited liability company with its principal place of 

business at 1111 Stewa1t Ave., Bethpage, NY I 1714. 

5. In preparation of my declaration, I requested from Altice's Data and Analytics team 

information regarding the number and location of Altice's broadband subscribers. The data I 

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received reflects that, as of December 2023, Altice provides broadband services to approximately 

4,519,954 total (i.e., residential and business) subscribers across 2 1 states. This data also reflects 

that approximately 4,169,032 of these are residential subscribers and that 2,6 I 9,800 of those 

residential subscribers, or 63%, are in New York, New Jersey, or Connecticut, areas that generally 

are part of the broader New York metropolitan region. I also requested data from the Data and 

Analytics team regarding the location of Altice's New York subscribers. The information that I 

received, which is dated as of December 2023, is broken down by city and county. Based on my 

review of this data, Altice has 1,695,829 total subscribers in New York and, of those, 1,050,095 

are in the Eastern District of New York. My understanding of the counties that comprise the 

Eastern District of New York is based on the following website: https://www.nyed.uscourts.gov/. 

This website reflects that the following New York counties are in the Eastern District of New 

York: Kings, Nassau, Queens, Richmond, and Suffolk. A true and correct copy of the abovereferenced website is attached hereto as Exhibit A. 

6. In preparation of my declaration, I also requested from the Data and Analytics team 

information regarding the location of Altice's subscribers in Texas. Like the above information 

regarding New York, this information also is dated as of December 2023, and is broken down by 

city and county. Based on my review of this data, Altice has 189,271 total subscribers in the 

counties that comprise the Eastern District of Texas. Of those, 3,439 are in the counties that 

comprise the Marshall Division. My understanding of the counties that comprise the Eastern 

District of Texas and its divisions is based on the following website: 

https://www.txed.uscourts.gov/court-locator. A true and correct copy of the above-referenced 

website is attached hereto as Exhibit B. 

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7. Altice's business, technical, and legal operations are based in its two headquarters, 

Altice USA's headquarters in Long Island City, NY, which is in Queens County, and CSC 

Holding's headquarters in Bethpage, NY, which is in Nassau County, or in nearby work facilities 

that also are in Nassau County. Specifically, virtually all of Altice's key executive, management, 

and operations-level personnel in customer care, products, marketing, network engineering, data, 

finance, and legal are located in these facilities. Further, the Shared Services team that deals with 

complaints of alleged copyright infringement and certain of Altice's actions in response is based 

in an Altice facility in Jericho, NY, which also is Nassau County. In preparation of my declaration, 

I also requested from Human Resources a report regarding the number of Altice employees in New 

York. As of December 3 1, 2023, Altice employed approximately 3,890 people in New York. 

8. Within the divisions and groups that I describe above are the following individuals 

who are the leads and/or are responsible for aspects of Altice's processes for responding to notices 

of alleged infringement and related issues: (I) William Heberer, SVP Legal, Altice USA, Long 

Island City, NY; (2) Michael Davis, Manager, HSD Security, Altice USA, Hicksville, NY; (3) 

Danny Holton, SVP. Business Engagement and Technology Strategy, Altice USA, Long Island 

City, NY; (4) Christine Cummings, VP, Acquisition and Base Management, Altice USA, Long 

Island City, NY; (5) David Kniffin, SVP Planning and Control, Altice USA, Bethpage, NY; (6) 

Shuvankar Roy, EVP Chief Customer Experience Officer, Altice USA, Long ls land City, NY; (7) 

Ahmed Fayed, Director, Corporate Customer Relations and Shared Services, Altice USA, 

Bethpage, NY; (8) Audrey Pinn, Director, Product Gro-wth & Value Added Services, Altice USA, 

Long Island City, NY; (9) Beth Rosenfeld, Senior Director, Executive Customer Relations, Altice 

USA, Bethpage, NY; and (10) Joe Foster, Director, Network Engineering, Altice USA, Bethpage, 

NY. 

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9. It is my understanding that the following individuals are former Altice employees 

who were responsible for aspects of Altice's processes for responding to notices of alleged 

infringement and related issues: (1) Robert Egan, former Manager, Intelligence & 

Investigations/HS Data Security, Altice USA, Hicksville, NY; (2) Marian O' Hagan, former 

Director of Customer Care, Bethpage, NY; (3) Nadir Nazarov, former SVP Network Engineering, 

Altice USA, Bethpage, NY. 

I 0. It is also my understanding that the following individuals are former Altice 

employees who left Altice in 2024: (I) Keith Agabob, (2) Dan Drysdale, and (3) Nadir Nazarov. 

Mr. Agabob and Mr. Nazarov ended their employment on January 1, 2024 and Mr. Drysdale ended 

his employment on January 5, 2024. 

11. Given the location of Altice's divisions and personnel, Altice's relevant documents 

largely are created and/or handled by individuals in these facilities. 

12. In preparation of my declaration, I gathered information regarding the manner in 

which Altice's documents are currently stored and accessed. Since mid-2021 , these documents 

have been stored with Google's SQL and Big Query cloud services and, accordingly, are accessible 

from Altice's offices. The Google SQL servers are in Berkeley County, South Carolina, whereas 

the Google Big Query servers are dynamic and, therefore, no specific location is ascertainable. 

George Ziegler, Altice USA 's VP, Data Warehouse Development, is the "Data Warehouse" lead 

and, in that role, is the subject matter expert on the accessibility of documents, data, and other 

information from the cloud or other sources. Mr. Ziegler works out of Altice's office in Bethpage, 

NY, which is in Nassau County. I also understand that, prior to mid-2021 , Altice's documents 

were stored on servers in its New York facilities, including Bethpage, NY and Hicksville, NY, 

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both within Nassau County. I understand that certain documents still are only stored on those 

servers, including the documents from Altice's Knowledge Database. 

13. In preparation of my declaration, I also requested from Human Resources a report 

of the number and location of Altice employees across the country. Based on my review of the 

report, I identified that Altice has employees who work at facilities of various sizes and types in 

30 states, including New York. In Texas, Altice has faci lities in Plano and Tyler, where the vast 

majority of the employees in those facilities work in non-senior management-level positions in 

sales and customer support, and none of the employees in those faci lities are responsible for 

handling complaints of copyright infringement. 

14. Altice also has retail stores around the country, including in Texas. In these 

locations, Altice provides customer support and sells products and services. The employees who 

work at these stores are not involved with the processing of complaints of copyright infringement. 

Altice's retail stores are managed at the corporate level from Altice USA's headquarters in Long 

Island City, New York and work faci lities in Bethpage, NY. 

15. Like most large ISPs, Altice also has many subsidiaries, which serve different 

purposes in connection with its various products, services, and partnerships. Attached hereto as 

Exhibit C is a true and correct copy of excerpts of Altice USA 's Form 10-K for the fiscal year 

ending December 31, 2022, which was filed on or around February 23, 2023. Altice USA 's Form 

I 0-K, Exhibit 21 lists 174 subsidiaries of Altice USA. Three of these subsidiaries are identified as 

being incorporated in Texas: Friendship Cable of Arkansas, Inc., Friendship Cable of Texas, Inc., 

and TCA Communications, LLC. These entities do not have any involvement in the processing of 

copyright notices or other issues that I understand would be relevant in this case. Attached hereto 

as Exhibit D is a true and correct copy of results from the Texas Secretary of State, Business 

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Organizations Inquiry, which shows that each of these entities is headquartered at I Ct. Square W, 

Long Island City, NY 11101, which is the same location as Altice USA's headquarters. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct. 

Executed on January 29, 2024 

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