CLRB Hanson Industries, LLC et al v. Google Inc.

Filing 316

Declaration of Rachel S. Black in Support of 315 MOTION for Settlement PLAINTIFFS NOTICE OF MOTION AND UNOPPOSED MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, PROVISIONAL CERTIFICATION OF NATIONWIDE SETTLEMENT CLASS, AND APPROVAL OF PROCEDURE FOR AND FORM OF NOTICE; AND MEMORANDUM I filed byCLRB Hanson Industries, LLC, Howard Stern. (Related document(s) 315 ) (Black, Rachel) (Filed on 3/26/2009)

CLRB Hanson Industries, LLC et al v. Google Inc.

Doc. 31

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LESTER L. LEVY (Admitted Pro Hac Vice) MICHELE FRIED RAPHAEL (Admitted Pro Hac Vice) WOLF POPPER LLP 845 Third Avenue New York, NY 10022 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail] E-Mail: [e-mail] MARC M. SELTZER (54534) SUSMAN GODFREY L.L.P. 1901 Avenue of the Stars, Suite 950 Los Angeles, CA 90067-6029 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail] Attorneys for Plaintiffs (See Signature Page for Additional Plaint iffs' Counsel) UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION CLRB HANSON INDUSTRIES, LLC d/b/a INDUSTRIAL PRINTING, and HOWARD STERN, on behalf of themselves and all others similarly situated, Plaint iffs, vs. GOOGLE, INC., Defendant. Case No. C 05-03649 JW PVT DECLARATION OF RACHEL S. BLACK IN SUPPORT OF PLAINTIFFS' MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, PROVISIONAL CERTIFICATION OF NATIONWIDE SETTLEMENT CLASS, AND APPROVAL OF PROCEDURE FOR AND FORM OF NOTICE Hearing: Time: Dept.: Judge: Monday, May 11, 2009 9:00 am. Courtroom 8 Honorable James W. Ware

1 DECLARATION OF RACHEL S. BLACK Case No. C 05-03649 JW
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Dockets.Justia.com

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I, Rachel S. Black, hereby declare and state as follows: 1. I am an attorney at Susman Godfrey L.L.P., and counsel for plaintiffs CLRB

Hanson Industries LLC d/b/a Industrial Printing and Howard Stern (collectively "Plaintiffs"), in the above-capt ioned action. Washington. I am a member in good standing with the bar of the State of

I am over the age of eighteen, attest to the following matters from personal

knowledge, and if called as a witness, could competently testify to the matters set forth herein. 2. Before reaching settlement, Susman Godfrey L.L.P. and Wolf Popper LLP

(collectively, "Representative Plaintiffs' Counsel") extensively analyzed the applicable law and facts of this case, which included reviewing thousands of pages of documents produced by Google and taking several depositions of Google representatives. Based on public data released by Google concerning the number of AdWords customers, Representative Plaintiffs' Counsel believe that the number of class members easily exceeds one thousand. 3. Settlement was achieved in this case as a result of vigorous, arm's-length

negotiations. Representative Plaintiffs' Counsel believe based on their analysis that the proposed settlement is eminently fair, reasonable, and adequate and warrants judicial approval. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Signed this 26th day of March, 2009, at Seattle, Washington. s/ Rachel S. Black Rachel S. Black

2 DECLARATION OF RACHEL S. BLACK Case No. C 05-03649 JW
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CERTIFICATE OF SERVICE I hereby certify that on the date written above, that I electronically filed the foregoing document with the Clerk of the Court using the CM/ECF system. The Court or the CM/ECF system will send notification of such filings to all CM/ECF participants, as follows: David T. Biderman Timothy J. Franks M. Christopher Jhang Farschad Farzan Sang (Alvin) Lee Daralyn Durie dbiderman@perkinsco ie.co m tfranks@perkinsco ie.co m cjhang@perkinsco ie.com ffarzan@perkinsco ie.co m [e-mail] [e-mail] s/ Rachel S. Black

1 CERT OF SERVICE FOR 3/26/09 BLACK DECL. Case No. C 05-03649 JW
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