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 7
Anthony Italiano Declaration

KASSRA P. NASSIRI (215405)
1 ([e-mail])
NASSIRI & JUNG LLP
2 47 Kearny Street, Suite 700
San Francisco, California 94108
3 Telephone: [phone]
Facsimile: [phone]
4
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]
8
9 ILAN CHOROWSKY (Pro Hac Vice)
([e-mail])
10 PROGRESSIVE LAW GROUP, LLC
1 N LaSalle Street, Suite 2255
60602
11 Chicago, IL(312) 787-2717
Telephone:
12 Facsimile: [phone]
13
14
15
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Attorneys for Plaintiffs and the Putative Class
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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In re GOOGLE REFERRER HEADER PRIVACY
19 LITIGATION
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Case No. 5:10-cv-04809-EJD
CLASS ACTION

_______________________________________
This Document Relates To: All Actions

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

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

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ITALIANO DECLARATION
5:10-CV-04809

1 Pursuant to 28 U.S.C. § 1746, I hereby declare and state as follows:
2

1.

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

3

2.

On or about April 17, 2012, I spoke with Michael Aschenbrener and provided him

4 with information regarding my experience with using Google as a search engine.
5

3.

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

6 to Class Counsel in aiding their investigation.
7

4.

I considered the likely time commitment that could accompany being named the

8 representative of a class action. I concluded, however, that attempting to right what I believed to
9 be an unlawful wrong perpetrated by the Defendant, and securing relief for others whom had
10 similarly been wronged, was the proper course of action.
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5.

Thus, I was willing to participate in and undertake all of the responsibilities and

12 risks attendant within bringing representative action.
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6.

At no time before or during this litigation was I involved in any pre-agreement

14 concerning any possible incentive award as a Class Representative. At no time before or during
15 this litigation and subsequent settlement was I led to believe that I would necessarily receive any
16 incentive award, let alone any specific amount.
17

7.

I was contacted by Michael Aschenbrener on numerous occasions during the course

18 of this litigation to answer questions, provide documents, verify the accuracy of certain
19 allegations, and generally assist with the litigation of this case.
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8.

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

21 on receiving any incentive award, let alone any specific amount.
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9.

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

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24 Dated: July 24, 2014
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/s/ Anthony Italiano
Anthony Italiano

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1

ITALIANO DECLARATION
5:10-CV-04809