Hepting et al v. AT&T Corp. et al

Filing 18

Declaration of Carolyn Jewel in Support of 16 MOTION for Preliminary Injunction filed byGregory Hicks, Erik Knutzen, Tash Hepting, Carolyn Jewel. (Related document(s) 16 ) (Kathrein, Reed) (Filed on 3/31/2006)

Hepting et al v. AT&T Corp. et al

Doc. 18

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ELECTRONIC FRONTIER FOUNDATION CINDY COHN (145997) [e-mail] LEE TIEN (148216) [e-mail] KURT OPSAHL (191303) [e-mail] KEVIN S. BANKSTON (217026) [e-mail] CORYNNE MCSHERRY (221504) [e-mail] JAMES S. TYRE (083117) [e-mail] 454 Shotwell Street San Francisco, CA 94110 Telephone: [phone] (fax) TRABER & VOORHEES BERT VOORHEES (137623) [e-mail] THERESA M. TRABER (116305) [e-mail] 128 North Fair Oaks Avenue, Suite 204 Pasadena, CA 91103 Telephone: [phone] (fax) Attorneys for Plaintiffs [Additional counsel appear on signature page.] LAW OFFICE OF RICHARD R. WIEBE RICHARD R. WIEBE (121156) [e-mail] 425 California Street, Suite 2025 San Francisco, CA 94104 Telephone: [phone] (fax)

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA TASH HEPTING, GREGORY HICKS, CAROLYN JEWEL and ERIK KNUTZEN, on Behalf of Themselves and All Others Similarly Situated,, Plaintiffs, v. AT&T CORP., et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. C-06-0672-VRW CLASS ACTION DECLARATION OF CAROLYN JEWEL IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Courtroom: Judge: 6, 17th Floor Hon. Vaughn Walker

DECLARATION OF CAROLYN JEWEL IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION
Dockets.Justia.com

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I, Carolyn Jewel, hereby declare: 1. I am a plaintiff in this action, and I reside in Petaluma, California. I am a database

administrator and author, and also take and teach classes at a local university. I have personal knowledge of the matters stated in this declaration and if called upon to do so, I could and would competently testify thereto. 2. I have been a subscriber and user of AT&T Corp.'s Worldnet dial-up Internet

service ("Worldnet service") since approximately June 2000. 3. 4. I use the Worldnet dial-up service in my home. I use it nearly every day. I use the Worldnet service for web browsing and to send and receive email. I use the

Worldnet service to engage in correspondence with individuals in foreign countries, including England, Germany and Indonesia, as well as correspondence with individuals in the United States. 5. I use the Worldnet service to send correspondence and engage in activities that I

expect to remain private, such as personal correspondence, banking, family matters, medical matters of concern to me and my family, correspondence with students, fellow-students and professors, and discussions regarding my published and in progress writing with my literary agent, editors, other authors and fans. 6. Since June 2000, I have sent and received emails from persons who are not

customers of the Worldnet service, as well as those who are customers of the Worldnet service and, to the best of my knowledge, those emails have traveled on the Worldnet service network. 7. I expected that my emails and other communications conducted through the

Worldnet service would remain private and would not be subjected to any form of government surveillance. I have never knowingly consented to any government surveillance of my

communications sent through or using the Worldnet service. 8. Since I learned of the government's domestic eavesdropping program and AT&T's

involvement in it, I have been concerned about the privacy of my communications. This concern has led me to question my use of the Worldnet service, including how, whether and/or the manner in which I respond to individuals via email, and my use of the Worldnet service to search for or disseminate information through the Internet. For example, with regard to an email correspondent
DECLARATION OF CAROLYN JEWEL IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION

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I, Reed R. Kathrein, am the ECF User whose ID and password are being used to file this

2 DECLARATION OF CAROLYN JEWEL IN SUPPORT OF MOTION FOR PRELIMINARY 3 INJUNCTION. In compliance with General Order 45, X.B., I hereby attest that Carolyn Jewel has 4 concurred in this filing. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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CERTIFICATE OF SERVICE I hereby certify that on March 31, 2006, I electronically filed the foregoing with the Clerk of

3 the Court using the CM/ECF system which will send notification of such filing to the e-mail 4 addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I have 5 mailed the foregoing document or paper via FedEx to the non-CM/ECF participants indicated on the 6 attached Manual Notice List. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 /s/ REED R. KATHREIN REED R. KATHREIN LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 100 Pine Street, 26th Floor San Francisco, CA 94111 Telephone: [phone] (fax) E-mail: [e-mail]

CAND-ECF

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Mailing Information for a Case 3:06-cv-00672-VRW
Electronic Mail Notice List
The following are those who are currently on the list to receive e-mail notices for this case. Stuart Bankston [e-mail]
Kevin

Ann Cohn [e-mail] [e-mail];[e-mail]
Cindy

A. Ericson [e-mail]
Bruce

D Friedman [e-mail] [e-mail]
Jeff

A. Isaacson [e-mail] [e-mail]
Eric

R. Kathrein [e-mail] [e-mail];[e-mail]
Reed

McSherry [e-mail]
Corynne

V. Morris [e-mail] [e-mail];[e-mail]
Maria

Opsahl [e-mail]
Kurt

Eve Scarlett [e-mail] [e-mail];[e-mail]
Shana

M. Traber, Esq [e-mail]
Theresa

Samuel Tyre [e-mail] [e-mail]
James

Voorhees [e-mail]
Bert

Manual Notice List
The following is the list of attorneys who are not on the list to receive e-mail notices for this case (who therefore require manual noticing). You may wish to use your mouse to select and copy this list into your word processing program in order to create notices or labels for these recipients.
Lee Tien

https://ecf.cand.uscourts.gov/cgi-bin/MailList.pl?814506106457448-L_293_0-1

3/30/2006

CAND-ECF
Electronic Frontier Foundation 454 Shotwell Street San Francisco, CA 94110 Lee Tien Electronic Frontier Foundation 454 Shotwell Street San Francisco, CA 94110

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https://ecf.cand.uscourts.gov/cgi-bin/MailList.pl?814506106457448-L_293_0-1

3/30/2006