In Re FACEBOOK INTERNET TRACKING LITIGATION

Filing 115

REPLY (re #110 MOTION to Compel DISCOVERY AND COMPLIANCE WITH PROTECTIVE ORDER ) filed bySharon Beatty. (Attachments: #1 Supplemental Declaration of David A. Straite, #2 Exhibit 1 to the Straite Declaration, #3 Exhibit 2 to the Straite Declaration, #4 Exhibit 3 to the Straite Declaration, #5 Exhibit 4 to the Straite Declaration, #6 Exhibit 5 to the Straite Declaration, #7 Exhibit 6 to the Straite Declaration)(Straite, David) (Filed on 4/6/2016)

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Stephen G. Grygiel (admitted pro hac vice)
SILVERMAN THOMPSON
SLUTKIN WHITE LLC
201 N. Charles Street, 26TH Floor
Baltimore, MD 21201
Tel.: [phone]
Fax: [phone]
[e-mail]

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.: [phone]
Fax: [phone]
[e-mail]

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Laurence D. King (206423)
Mario Choi (243409)
KAPLAN FOX & KILSHEIMER LLP
350 Sansome Street, 4th Floor
San Francisco, CA 94104
Tel.: [phone]
Fax: [phone]
[e-mail]

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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No. 5:12-md-02314-EJD
IN RE: FACEBOOK, INC. INTERNET
TRACKING LITIGATION

SUPPLEMENTAL DECLARATION OF
DAVID A. STRAITE IN SUPPORT OF
PLAINTIFFS’ MOTION TO COMPEL
DISCOVERY AND TO COMPEL
COMPLIANCE WITH PROTECTIVE
ORDER

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F.R.C.P. 26(c) and 37(a)
N.D. Cal. L.R. 37-1 and 37-2
Date:
Time:
Courtroom:
Judge:
Trial Date:

April 28, 2016
9:00 a.m.
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The Honorable Edward J. Davila
None Set

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SUPPLEMENTAL DECLARATION OF DAVID A. STRAITE
No. 5:12-md-02314-EJD

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SUPPLEMENTAL DECLARATION OF DAVID A. STRAITE

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I, David A. Straite, declare as follows:

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1.

I am an attorney admitted pro hac vice to practice before this Court in this matter. I am

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an attorney at the law firm of Kaplan Fox & Kilsheimer LLP, Interim Co-Lead Class Counsel in this

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class action against Defendant Facebook, Inc.

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2.

I submit this supplemental declaration in support of plaintiffs’ motion to compel (the

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“Motion”). The following statements are based on my personal knowledge and review of the files in

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this case and, if called on to do so, I could and would testify competently thereto.

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3.

Attached hereto as Exhibit 1 is a true and correct copy of a document produced by

defendant in this action and bearing bates number FB_MDL_00000251 on the first page.
4.

Attached hereto as Exhibit 2 is a true and copy of the 27-page production of documents I

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received from Facebook counsel on April 5, 2016. The transmittal letter was dated April 4, 2016 and

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the letter and the production were sent by Fedex overnight delivery.

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5.

Attached hereto as Exhibit 3 is a true and correct copy of defendant’s Rule 26(a) initial

disclosures dated July 27, 2012 and signed by outside counsel Matthew D. Brown.
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Attached hereto as Exhibit 4 is a true and correct copy of a document produced by

plaintiffs bearing bates number FB_MDL2314_PLAINTIFF_00000035 on the first page.
7.

Attached hereto as Exhibit 5 is a true and correct copy of a document produced by

plaintiffs bearing bates number FB_MDL2314_PLAINTIFF_00000337 on the first page.
8.

Attached hereto as Exhibit 6 is a true and correct copy of a document produced by

plaintiffs bearing bates number FB_MDL2314_PLAINTIFF_00000113 on the first page.
I declare under penalty of perjury under the laws of the United States that the foregoing is true
and correct. Executed on this 6th day of April, 2016, at New York, NY.

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/s/ David Straite
David A. Straite

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-2SUPPLEMENTAL DECLARATION OF DAVID A. STRAITE
No. 5:12-md-02314-EJD