Hibnick v. Google Inc.

Filing 131

Declaration of Gary E. Mason in Support of 130 Notice (Other), Notice (Other) Class Counsel's Final Application for Reimbursement of Expenses filed byJohn Case, Eva Hibnick, Lauren Maytin, Mark Neyer, Andranik Souvalian, Katherine C Wagner. (Attachments: # 1 Exhibit 1 Mason LLP Expenses, # 2 Exhibit 2 Rubenstein Declaration and Expenses)(Related document(s) 130 ) (Mason, Gary) (Filed on 6/10/2011)

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Gary E. Mason (pro hac vice)
[e-mail]
Donna F. Solen (pro hac vice)
[e-mail]
MASON LLP
1625 Massachusetts Ave., NW
Washington, DC 20036
Telephone: [phone]
Facsimile: [phone]
Michael F. Ram (SBN 104805)
[e-mail]
RAM & OLSON LLP
555 Montgomery Street, Suite 820
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs and the Proposed Class

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THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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No.: 10-00672 JW

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IN RE GOOGLE BUZZ USER PRIVACY
LITIGATION

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This Document Relates To:
ALL CASES

DECLARATION OF GARY E. MASON,
ESQ. IN SUPPORT OF SUPPLEMENTAL
APPLICATION FOR REIMBURSEMENT
OF EXPENSES

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JUDGE:
Hon. James Ware
MEDIATOR: Hon. Fern Smith (Ret.)

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Original Complaint Filed: 02/17/10
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I, GARY E. MASON, under of penalty of perjury, state and aver as follows:
1.

I am Lead Class Counsel for the Settlement Class.

2.

Mason LLP has incurred additional unreimbursed expenses of $7,400.07 since

December 20, 2010. These expenses were incurred principally in connection with travel from
Washington D.C., to San Jose, California for the Final Approval Hearing, for a payment to The Rose
Foundation, and for research conducted in connection with Plaintiffs’ responses to various

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Case No. 10-0672 JW – DECLARATION OF GARY E. MASON IN SUPPORT OF FINAL APPLICATION FOR
ATTORNEYS’FEES AND REIMBURSEMENT OF EXPENSES

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objections filed to the Settlement. A summary of those expenses is attached as Exhibit 1.
3.

The Law Office of William B. Rubenstein has incurred additional unreimbursed

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expenses of $7,284.09 since December 20, 2010. See Supplemental Declaration of William B.

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Rubenstein in Support of Application for Attorneys’ Fees and Reimbursement of Expenses, Exhibit

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2, hereto. These expenses were incurred principally in connection with travel from Boston,

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Massachusetts to San Jose, California for the Final Approval Hearing and for a payment made to

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The Rose Foundation.

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4.

Ram & Olson has incurred additional unreimbursed expenses of $262.77 since

December 20, 2010. These expenses were incurred principally in connection with in-house copying
and FedEx charges.
5.

Pursuant to the above, Class Counsel seek reimbursement of unreimbursed expenses

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in the amount of $14,946.93, in addition to the $29,286.85, previously requested, for a total amount

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of $44,233.78.

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6.

Class Counsel agreed to pay The Rose Foundation a total of $60,000.00 for services it

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provided in connection with the nominations of cy pres recipients. These services includes

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preparation of an application form, dissemination of the application to Rose’s privacy database,

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responding to prospective applicant inquiries, review of all nominations for conformity with

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requirements, and organization of nominations received. Class Counsel have paid The Rose

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Foundation $10,000.00 to date as a retention payment; $50,000.00 remains outstanding.

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7.

The Garden City Group was selected to administer certain aspects of the notice

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program including creation and maintenance of an official website, www.buzzclassaction.com, and

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the administration of communications with class members, including questions and requests for

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exclusions. The Garden City Group has invoiced Class Counsel $62,777.44 for services rendered in

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connection with Notice and Distribution Administration from project inception through completion.

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Case No. 10-0672 JW – DECLARATION OF GARY E. MASON IN SUPPORT OF FINAL APPLICATION FOR
ATTORNEYS’FEES AND REIMBURSEMENT OF EXPENSES

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I declare under penalty of perjury that the foregoing is true and correct.

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Executed on the 10th day of June, 2011, in Washington, D.C.

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By:

/s/ Gary E. Mason
Gary E. Mason
Mason LLP
1625 Massachusetts Ave., NW
Suite 605
Washington, DC 20036

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Case No. 10-0672 JW – DECLARATION OF GARY E. MASON IN SUPPORT OF FINAL APPLICATION FOR
ATTORNEYS’FEES AND REIMBURSEMENT OF EXPENSES