"In Re: Facebook Privacy Litigation"

Filing 15

Declaration of Kassra P. Nassiri in Support of 14 MOTION to Relate Case filed byMike Robertson. (Related document(s) 14 ) (Nassiri, Kassra) (Filed on 7/21/2010)

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KASSRA P. NASSIRI (215405) [e-mail] CHARLES H. JUNG (217909) [e-mail] NASSIRI & JUNG LLP 251 Kearny Street, Suite 501 San Francisco, California 94108 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR PLAINTIFF MIKE ROBERTSON Robertson v. Facebook, Inc., No. 10-cv-02408-JF UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION DAVID GOULD, an individual, on behalf of himself and all others similarly situated, Plaintiff, v. FACEBOOK, INC., a Delaware corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Case No. 10-cv-02389-JW DECLARATION OF KASSRA P. NASSIRI IN SUPPORT OF ADMINISTRATIVE MOTION TO CONSIDER WHETHER CASES SHOULD BE RELATED

I, Kassra P. Nassiri, declare as follows: 1. I am an attorney licensed to practice law in the state of California and a

partner of the law firm of Nassiri & Jung LLP, counsel of record for plaintiff Mike Robertson ("Plaintiff Robertson"), Case No. 10-cv-02408-JF. I have personal knowledge of the facts below and could and would testify competently to them if called as a witness. I submit this declaration pursuant to Civil Local Rule 7-11(a) and in support of Plaintiff Robertson's Administrative Motion to Consider Whether Cases Should Be Related ("Administrative Motion").

DECLARATION OF KASSRA P. NASSIRI ISO ADMINISTRATIVE MOTION TO RELATE CASES

CASE NO. 10-CV-02389-JW

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2.

On July 15, 19 and 20, I spoke with Matthew D. Brown, counsel for defendant

Facebook, regarding Plaintiff Robertson's Administrative Motion. Mr. Brown stated that Facebook agrees that the Robertson and Gould matters should be related under Local Rule 3-12. Mr. Brown, however, declined to stipulate to the Administrative Motion because Facebook plans to file its own motion to determine relatedness.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 21, 2010 in San Francisco, California.

By:

/s/ Kassra P. Nassiri Kassra P. Nassiri

DECLARATION OF KASSRA P. NASSIRI ISO ADMINISTRATIVE MOTION TO RELATE CASES 2

CASE NO. 10-CV-02389-JW