Campbell et al v. Facebook Inc.
Filing
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Administrative Motion to File Under Seal re Plaintiffs' Response to Defendant's Objection to and Request to Strike New Evidence filed by Matthew Campbell, Michael Hurley. (Attachments: # 1 Declaration of Melissa Gardner, # 2 Proposed Order, # 3 Exhibit A-Filed Under Seal, # 4 Exhibit B-Redacted, # 5 Certificate/Proof of Service)(Gardner, Melissa) (Filed on 3/9/2016)
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Michael W. Sobol (State Bar No. 194857)
msobol@lchb.com
David T. Rudolph (State Bar No. 233457)
drudolph@lchb.com
Melissa Gardner (State Bar No. 289096)
mgardner@lchb.com
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
275 Battery Street, 29th Floor
San Francisco, CA 94111-3339
Telephone: 415.956.1000
Facsimile: 415.956.1008
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Hank Bates (State Bar No. 167688)
hbates@cbplaw.com
Allen Carney
acarney@cbplaw.com
David Slade
dslade@cbplaw.com
CARNEY BATES & PULLIAM, PLLC
11311 Arcade Drive
Little Rock, AR 72212
Telephone: 501.312.8500
Facsimile: 501.312.8505
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Attorneys for Plaintiffs and the Proposed Class
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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OAKLAND DIVISION
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MATTHEW CAMPBELL and MICHAEL
HURLEY, on behalf of themselves and all
others similarly situated,
Plaintiff,
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v.
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FACEBOOK, INC.,
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Defendant.
Case No. C 13-05996 PJH (MEJ)
DECLARATION OF MELISSA GARDNER
IN SUPPORT OF PLAINTIFFS’
ADMINISTRATIVE MOTION TO FILE
UNDER SEAL RE RESPONSE TO
DEFENDANT’S “OBJECTION TO AND
REQUEST TO STRIKE NEW EVIDENCE
AND MISSTATEMENTS OF FACT”
Judge: Honorable Phyllis J. Hamilton
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DECL. OF MELISSA GARDNER ISO MOTION TO SEAL
CASE NO. 13-CV-05996-PJH (MEJ)
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I, Melissa Gardner, declare:
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I am an attorney in the law firm of Lieff, Cabraser, Heimann & Bernstein, LLP, a member
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of the State Bar of California, and am admitted to practice before the United States District Court
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for the Northern District of California. I am one of the counsel for Plaintiffs in this action. I
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make this declaration based on my own personal knowledge. If called upon to testify, I could and
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would testify competently to the truth of the matters stated herein.
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1.
I submit this Declaration in Support of Plaintiffs’ Administrative Motion to File
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Under Seal in connection with Plaintiffs’ Response to Defendant’s Objection to and Request to
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Strike New Evidence and Misstatements of Fact (“Response”).
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2.
Attached hereto as Exhibit A is a true and correct copy of the unredacted version
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of the Response. Highlighted text in Exhibit A is text that Plaintiffs propose to redact on the
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grounds that such text contains information that Defendant (the designating party) has designated
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“HIGHLY CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
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3.
Attached hereto as Exhibit B is a true and correct copy of a redacted version of the
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Response. Redacted text in Exhibit B is text that Plaintiffs propose to redact on the grounds that
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such text contains information that Defendant (the designating party) has designated “HIGHLY
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CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
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4.
Plaintiffs take no position on whether the text of the Response designated for
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redaction satisfies the requirements for sealing. Plaintiffs specifically reserve the right to
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challenge any “HIGHLY CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
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EYES ONLY” designation under the Stipulated Protective Order as well as the sealability of
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these documents under Civil Local Rule 79-5.
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I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.
Executed this 9th day of March, 2016, in San Francisco, California.
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
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By:
/s/Melissa Gardner
Melissa Gardner
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DECL. OF MELISSA GARDNER ISO MOTION TO SEAL
CASE NO. 13-CV-05996-PJH (MEJ)
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