In re Google Referrer Header Privacy Litigation

Filing 66

MOTION for Attorney Fees Expenses and Costs filed by Paloma Gaos. Motion Hearing set for 8/29/2014 09:00 AM in Courtroom 4, 5th Floor, San Jose before Hon. Edward J. Davila. Responses due by 8/8/2014. Replies due by 8/22/2014. (Attachments: #1 Declaration Aschenbrener, #2 Declaration Nassiri, #3 Declaration Chorowsky, #4 Declaration Class Admin, #5 Declaration Dore, #6 Declaration Gaos, #7 Declaration Italiano, #8 Declaration Priyev, #9 Proposed Order for Final Approval and Fees, #10 Proposed Order Final Judgment)(Aschenbrener, Michael) (Filed on 7/25/2014)

Exhibit 6
Paloma Gaos Declaration

KASSRA P. NASSIRI (215405)
(knassiri@nassiri -j ung. com)
NASSIRI & JUNG LLP
2 47 Kearny Street, Suite 700
San Francisco, California 94108
3 Telephone: [phone]
Facsimile: [phone]
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MICHAEL J. ASCHENBRENER
5 ([e-mail]) (277114)
ASCHENBRENER LAW, P.C.
6 795 Folsom Street, First Floor
San Francisco, CA 94107
7 Telephone: [phone]
Facsimile: [phone]
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ILAN CHOROWSKY (Admitted Pro Hac Vice
([e-mail])
PROGRESSIVE LAW GROUP, LLC
1 N LaSalle Street, Suite 2255
Chicago IL 60602
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs and the Putative Class

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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In re GOOGLE REFERRER HEADER PRIVACY
LITIGATION

Case No. 5:10-cv-04809-EJD
CLASS ACTION

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This Document Relates To: All Actions

GAOS DECLARATION IN
SUPPORT OF PLAINTIFFS'
MOTION FOR FINAL
APPROVAL OF CLASS ACTION
SETTLEMENT, FEES,
EXPENSES, AND INCENTIVE
AWARDS
Date:
Time:
Place:
Judge:

August 29, 2014
9:00a.m.
Courtroom 4, 5th Floor
Hon. Edward J. Davila

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GAO DEC LARA T!ON

5: I0-CV-04809

1 Pursuant to 28 U.S.C. § 1746, I, Paloma Gaos, hereby declare and state as follows:
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1.

I am a Class Representative in the above-captioned action.

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2.

In October 2010, I spoke with Class Counsel Kassra Nassiri and provided him with

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information regarding my experience with and concerns about using Google as a search engine.
3.

Thereafter and before the filing of the Complaint, I provided substantial assistance

to Mr. Nassiri in aiding his investigation.

4.

Before agreeing to bring this lawsuit, I considered the likely time commitment

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involved as a named the representative in a class action. I concluded that attempting to right what I

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believed to be an unlawful wrong perpetrated by Google, and securing relief for others who had

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similarly been wronged, was the proper course of action.
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Thus, I was willing to participate in and accept all of the responsibilities and risks

attendant within bringing a representative action.

6.

At no time before or during this litigation did I enter into any agreement concerning

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any possible incentive award as a Class Representative. At no time before or during this litigation

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and subsequent settlement was I led to believe that I would necessarily receive any incentive

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award, let alone any specific amount.

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7.

I was contacted by Class Counsel on numerous occasions during the course of this

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litigation to answer questions, provide documents, verify the accuracy of certain allegations, and

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generally assist with the litigation ofthis case.

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8.

At no time did I condition my agreement to the proposed settlement of this matter

on receiving any incentive award, let alone any specific amount.

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I declare under penalty of perjury under the laws of the United States of America that the

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foregoing is true and correct.

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Dated: July 24, 2014
Paloma Gaos

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GAOS DECLARATION

5: I 0-CV-04809