Uber MDL 3084 Discovery Index: Internal Safety Exhibits & Evidence

Discovery Documents & Trial Exhibits

While Pretrial Orders (PTOs) establish the framework of the litigation, the following documents represent key evidence produced during the discovery phase. These exhibits provide insight into Uber’s internal safety protocols, predictive modeling, and incident prevention strategies.

This repository contains internal documents, technical reports, and evidentiary exhibits produced during discovery in the Uber MDL 3084 litigation. These files provide a granular look at Uber’s internal safety systems and risk-assessment methodologies.

07/23/2025: [Discovery Exhibit P-01682] Internal Technical Data: US & Latin America Production Model Feature Importance [PDF]

07/23/2025: [Discovery Exhibit P-01676] Internal Technical Document: Global Safety Model Feature Definitions [PDF]

07/17/2025: [Discovery Exhibit P-01687] Internal Data Exhibit: S-RAD Risk Assessment – Jaylynn Dean [Native Excel]

03/06/2024: [Discovery Exhibit P-01366] Internal Technical Presentation: S-RAD Leadership Update – Technical Issues & Global Safety Efficacy [PDF]

03/06/2024: [Discovery Exhibit P-01366] Internal Technical Presentation: S-RAD Leadership Update – Technical Issues & Global Safety Efficacy [PDF]

07/27/2023: [Discovery Exhibit P-01667] Internal Technical Narrative: Safety & Insurance H2 2023 Strategic Plans [PDF]

04/03/2023: [Discovery Exhibit P-01681] Internal Technical Presentation: Baseline S-RAD Global Model Performance [PDF]

04/13/2021: [Discovery Exhibit P-01630] Internal Memorandum: S-RAD Model Review – Gender Variables & Trigger Rate Selection [PDF]

11/18/2020: [Discovery Exhibit P-01689] Internal Presentation: Stand for Safety Program Review – Working Slides [PDF]

11/18/2020: [Discovery Exhibit P-01689] Internal Presentation Slide: S-RAD – The Concept [PDF]

01/03/2020: [Discovery Exhibit P-01573] Social Media Exhibit: Roger Kaiser Public Statements on Safety Reporting [PDF]

08/17/2018: [Discovery Exhibit P-01699] Internal Presentation: Safety Trends and Insights – Sexual Assault and Misconduct [PDF]

07/01/2018: [Discovery Exhibit P-01711] Internal Technical Report: S-RAD Sexual Assault Prevention Model Overview [PDF]

11/16/2017: [Discovery Exhibit P-01711] Internal Technical Document: S-RAD Model Overview [PDF]

07/12/2017: [Discovery Exhibit P-01698] Internal Technical Report: Sexual Assault Trends and Correlates [PDF]

02/06/2017: [Discovery Exhibit P-01696] Internal Presentation: Preventing Sexual Assaults – Strategic Initiatives [PDF]

02/01/2017: [Discovery Exhibit P-01696] Internal Technical Report: Preventing Sexual Assaults – Trends, Correlates, and Baseline Risk Model [PDF]

03/28/2016: [Discovery Exhibit P-01701] Internal Technical Report: Bouncer v3 Safety Incident Prediction & Prevention [PDF]