"In Re: Facebook Privacy Litigation"

Filing 62

Declaration of William OHara, Karen Bryant, Iris Phee, Christopher Brock in Support of 59 Brief, Plaintiff O'Hara's and Bryant's Response to this Court's 47 November 15, 2010 Order Re: Consolidation and Appointment of Co-Lead Plaintiff and Co-Lead Counsel filed by Christopher Brock, Karen Bryant. (Related document(s) 59 ) (Gibbs, Eric) (Filed on 11/22/2010) Modified on 11/23/2010 (cv, COURT STAFF).

Gould v. Facebook, Inc.

Doc. 62

1 MILBERG LLP JEFF S. WESTERMAN (SBN 94559) 2 [e-mail] SABRINA S. KIM (SBN 186242) 3 [e-mail] One California Plaza 4 300 S. Grand Avenue, Suite 3900 Los Angeles, California 90071 5 Telephone: [phone] Facsimile: [phone] 6 GIRARD GIBBS LLP 7 ERIC H. GIBBS (SBN 178658) [e-mail] 8 DYLAN HUGHES (SBN 209113) DAVID STEIN (SBN 257465) 9 601 California Street, 14th Floor San Francisco, California 94104 10 Telephone: [phone] Facsimile: [phone] 11 Proposed Lead Counsel 12 UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA 14 15 In Re: Facebook Privacy Litigation 16 17 18 19 20 21 22 23 24 THIS DOCUMENT ALSO RELATES TO: 25 Graf v. Zynga Game Network, Inc. 26 27 28 Albini v. Zynga Game Network, Inc., et al. Gudac et al. v. Zynga Game Network, Inc. 1
JOINT DECLARATION IN SUPPORT OF THE MOTION TO CONSOLIDATE ZYNGA ACTIONS, APPOINT LEAD PLAINTIFFS, AND APPROVE LEAD PLAINTIFFS' SELECTION OF LEAD COUNSEL Dockets.Justia.com

CASE NO. C 10-02389 JW CLASS ACTION JOINT DECLARATION ISO PLAINTIFFS BRYANT AND O'HARA'S REQUEST TO: (1) Consolidate the Zynga Actions as the In re: Zynga Litigation (2) Appoint O'Hara & Bryant Lead Plaintiffs (3) Appoint Milberg LLP and Girard Gibbs LLP Lead Counsel

CASE NO. 10-4680 CASE NO. 10-4723 CASE NO. 10-4793

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Schreiber v. Zynga Game Network, Inc. Swanson v. Zynga Game Network, Inc. Carmel-Jessup v. Facebook, Inc., et al. Phee et al. v. Facebook Inc., et al. Bryant et al. v. Facebook, Inc. et al.

CASE NO. 10-4794 CASE NO. 10-4902 CASE NO. 10-4930 CASE NO. 10-4935 CASE NO. 10-5192

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JOINT DECLARATION IN SUPPORT OF THE MOTION TO CONSOLIDATE ZYNGA ACTIONS, APPOINT LEAD PLAINTIFFS, AND APPROVE LEAD PLAINTIFFS' SELECTION OF LEAD COUNSEL

1

William O'Hara, Iris Phee, Karen Bryant, and Christopher Brock, hereby declare as

2 follows: 3 4 5 6 7 1. We are users of Facebook's social networking website, we have used Zynga

applications on the Facebook platform, and we have clicked on at least one advertisement while doing so. 2. We are informed of the proceedings to date in this litigation and support

8 consolidation of the Zynga cases filed in October and November 2010 to promote efficiency. 9 10 11 12 13 14 15 Zynga cases and to have the firms of Milberg LLP and Girard Gibbs LLP appointed as Lead Counsel in the consolidated litigation. 5. O'Hara and Bryant understand that their Lead Plaintiff duties will include fairly 3. We know that the Court invited the plaintiffs to submit motions for appointment

of Lead Plaintiff and Lead Counsel. 4. We seek to have O'Hara and Bryant named Lead Plaintiff in the consolidated

16 and adequately representing the best interests of the class by actively participating in the 17 litigation, staying informed about the proceedings, monitoring and supervising Lead Counsel, 18 19 20 21 and making important decisions. They are ready to undertake these duties and are confident that they can and will fulfill them. 6. Plaintiffs Phee and Brock understand that the appointment of more than two Lead

22 Plaintiff's is not necessary and, therefore, are not moving as Proposed Lead Plaintiff and support 23 the appointment of co-plaintiffs O'Hara and Bryant as Lead Plaintiff and Milberg and Girard 24 Gibbs as Lead Counsel. Plaintiffs Phee and Brock will continue as plaintiffs and may move for 25 appointment as class representatives at the appropriate time. 26 27 28 // // 1
JOINT DECLARATION IN SUPPORT OF THE MOTION TO CONSOLIDATE ZYNGA ACTIONS, APPOINT LEAD PLAINTIFFS, AND APPROVE LEAD PLAINTIFFS' SELECTION OF LEAD COUNSEL