In Re FACEBOOK INTERNET TRACKING LITIGATION
Filing
108
MOTION for Protective Order TEMPORARILY STAYING FURTHER DISCOVERY PENDING RESOLUTION OF MOTION TO DISMISS SECOND AMENDED CONSOLIDATED COMPLAINT, AND MEMORANDUM OF POINTS AND AUTHORITIES filed by Facebook Inc.. Motion Hearing set for 4/28/2016 09:00 AM in Courtroom 4, 5th Floor, San Jose before Hon. Edward J. Davila. Responses due by 3/16/2016. Replies due by 3/23/2016. (Attachments: #1 Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #2 Exhibit A to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #3 Exhibit B to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #4 Exhibit C to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #5 Exhibit D to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #6 Exhibit E to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #7 Exhibit F to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #8 Exhibit G to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #9 Exhibit H to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #10 Proposed Order (Brown, Matthew) (Filed on 3/2/2016) Modified on 3/16/2016 (cv, COURT STAFF).
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COOLEY LLP
MICHAEL G. RHODES (116127)
(rhodesmg@cooley.com)
MATTHEW D. BROWN (196972)
(brownmd@cooley.com)
JEFFREY M. GUTKIN (216083)
(jgutkin@cooley.com)
KYLE C. WONG (224021)
(kwong@cooley.com)
ADAM C. TRIGG (261498)
(atrigg@cooley.com)
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
(415) 693-2000
Facsimile:
(415) 693-2222
Attorneys for Defendant
FACEBOOK, INC.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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In re: Facebook Internet Tracking Litigation
Case No. 5:12-md-02314 EJD
EXHIBIT C TO DECLARATION OF KYLE
C. WONG IN SUPPORT OF DEFENDANT
FACEBOOK, INC.’S MOTION FOR
PROTECTIVE ORDER
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Date:
Time:
Courtroom:
Judge:
Trial Date:
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April 28, 2016
9:00 a.m.
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Edward J. Davila
None Set
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EXHIBIT C
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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO
1.
EXHIBIT C TO WONG DECLARATION ISO
FACEBOOK’S MOTION FOR PROTECTIVE ORDER
CASE NO. 5:12-MD-02314 EJD
Wong, Kyle
From:
Sent:
To:
Cc:
Subject:
Attachments:
David Straite
Tuesday, August 20, 2013 1:28 PM
Wong, Kyle
'Jim Frickleton'; 'Stephen Grygiel'
In re: Facebook Internet Tracking Litig. -- confidentiality stipulation
Facebook Internet Tracking MDL -- Revised draft confidentiality stip 20 AUG 2013
revision.docx
Dear Kyle,
It has been a while since we’ve emailed, and I hope you are doing well. I write with respect to the Facebook Internet
Tracking MDL.
The last time we emailed was in February, and I believe we had just about finished the confidentiality
stipulation/order. I sent you a revision on February 12, 2013, and you sent back your comments on February 20,
2013. We are now prepared to accept all of your comments and revisions mentioned in your Feb. 20 email. I’ve
attached the most recent draft to this email, with edits to reflect your Feb. 20 email. I also added a new section 13.6 to
reflect our (tentative) agreement with respect to the priv logs, edited to include the two in‐house lawyers you
requested.
If the terms are still acceptable, I will remove track‐changes, re‐circulate, and have our local counsel file – unless you
prefer that Cooley file. We are fine either way.
Finally, as you know, my former firm (Stewarts Law) closed its US offices; please note that I have joined Kaplan Fox as Of
Counsel in the New York office and my contact information is below. I also still have my solo practice on the side
(STRAITE PLLC) and thus you can always contact me at david@straite.com; both email addresses get to me in real
time. Feel free to use whichever address is easier.
Kindest regards,
David A. Straite
Kaplan Fox & Kilsheimer LLP
850 Third Avenue
New York, NY 10022
Tel. 212.687.1980
Fax 212.687.7714
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