In Re FACEBOOK INTERNET TRACKING LITIGATION
Filing
105
DECLARATION of Stephen G. Grygiel in Opposition to #101 MOTION to Dismiss Defendant Facebook, Inc.s Motion to Dismiss Plaintiffs Second Amended Consolidated Class Action Complaint (Fed. R. Civ. P. 12(b)(1) & 12(b)(6)) filed byPerrin Aikens Davis, Brian K. Lentz, Cynthia D. Quinn, Matthew J. Vickery. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5)(Related document(s) #101 ) (Straite, David) (Filed on 2/18/2016)
1
2
3
4
5
Stephen G. Grygiel (admitted pro hac vice)
SILVERMAN THOMPSON
SLUTKIN WHITE LLC
201 N. Charles Street, 26TH Floor
Baltimore, MD 21201
Tel.: (410) 385-2225
Fax: (410) 547-2432
sgrygiel@mdattorney.com
Frederic S. Fox (admitted pro hac vice)
David A. Straite (admitted pro hac vice)
KAPLAN FOX & KILSHEIMER LLP
850 Third Avenue, 14th Floor
New York, NY 10022
Tel.: (212) 687-1980
Fax: (212) 687-7714
dstraite@kaplanfox.com
6
Laurence D. King (206423)
Mario Choi (243409)
KAPLAN FOX & KILSHEIMER LLP
350 Sansome Street, 4th Floor
San Francisco, CA 94104
Tel.: (415) 772-4700
Fax: (415) 772-4707
lking@kaplanfox.com
7
8
9
10
11
12
13
14
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
15
16
17
18
19
20
21
22
No. 5:12-md-02314-EJD
IN RE: FACEBOOK, INC. INTERNET
TRACKING LITIGATION
DECLARATION OF STEPHEN G.
GRYGIEL IN SUPPORT OF PLAINTIFFS’
MEMORANDUM OF POINTS AND
AUTHORITIES IN OPPOSITION TO
DEFENDANT FACEBOOK’S MOTION TO
DISMISS
N.D. Cal. L.R. 7-11 and 79-5
Next Hearing Date: April 28, 2016
23
Judge: The Honorable Edward J. Davila
24
25
26
27
28
DECLARATION OF STEPHEN G. GRYGIEL IN SUPPORT OF PLAINTIFFS’ MEMORANDUM
OF POINTS AND AUTHORITIES
No. 5:12-md-02314-EJD
1
DECLARATION OF STEPHEN G. GRYGIEL
2
I, Stephen G. Grygiel, declare as follows:
3
1.
I am an attorney admitted pro hac vice to practice before this Court in this matter. I am
4
an attorney at the law firm of Silverman Thompson Slutkin White LLC, Interim Co-Lead Class
5
Counsel in this class action against Defendant Facebook Inc.
6
2.
I submit this declaration in support of plaintiffs’ Memorandum of Points and Authorities
7
in Opposition to Facebook’s Motion to Dismiss (the “Memorandum”). The following statements are
8
based on my personal knowledge and review of the files in this case and, if called on to do so, I could
9
and would testify competently thereto.
10
11
12
13
14
3.
Attached hereto as Exhibit 1 is a true and correct copy of Senate Report 109-14
(February 28, 2005), related to the Class Action Fairness Act of 2005.
4.
Attached hereto as Exhibit 2 is a true and correct copy of Senate Report 99-541 (October
17, 1986), related to the Electronic Communications Privacy Act of 1986.
5.
Attached hereto as Exhibit 3 is a true and correct copy of House Report 107-236
15
(October 11, 2011), related to a bill to Provide Appropriate Tools Required to Intercept and Obstruct
16
Terrorism (“PATRIOT”) Act of 2001.
17
6.
Attached hereto as Exhibit 4 is a true and correct copy of the official French language
18
decision of the commission nationale de l’informatique et des libertés (“CNIL”) dated January 26,
19
2016, No. 2016-007, as provided on the CNIL website.
20
21
7.
Attached hereto as Exhibit 5 is a true and correct copy of the unofficial English language
decision of the CNIL dated January 26, 2016, No. 2016-007, as provided on the CNIL website.
22
23
24
25
I declare under penalty of perjury under the laws of the United States that the foregoing is true
and correct. Executed on this 18th day of February, 2016, at Baltimore, Maryland.
26
27
/s/ Stephen G. Grygiel
Stephen G. Grygiel
28
-2DECLARATION OF STEPHEN G. GRYGIEL IN SUPPORT OF PLAINTIFFS’ MEMORANDUM
OF POINTS AND AUTHORITIES
No. 5:12-md-02314-EJD
1
2
ATTESTATION OF E-FILED SIGNATURE
I, David A. Straite, court-appointed interim lead counsel for the proposed Class, am the ECF
3
User whose ID and password are being used to file this Declaration of Stephen Grygiel in Support of
4
Plaintiffs’ Memorandum. In compliance with Civil L.R. 5-1(i)(3), I hereby attest that Stephen Grygiel
5
has concurred in this filing.
6
7
/s/ David A. Straite
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-3DECLARATION OF STEPHEN G. GRYGIEL IN SUPPORT OF PLAINTIFFS’ MEMORANDUM
OF POINTS AND AUTHORITIES
No. 5:12-md-02314-EJD
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?