Campbell et al v. Facebook Inc.

Filing 219

NOTICE of Refiling re Motion to Compel Discovery and Supporting Documents by Matthew Campbell, Michael Hurley re 218 Order on Administrative Motion to File Under Seal. (Attachments: # 1 Exhibit 1 - Replacement for Dkt. 205-4, # 2 Exhibit 2 - Replacement for Dkt. 205-6, # 3 Exhibit 3 - Replacement for Dkt. 205-8, # 4 Exhibit 4 - Replacement for Dkt. 205-10, # 5 Exhibit 5 - Replacement for Dkt. 205-12, # 6 Exhibit 6 - Replacement for Dkt. 205-16, # 7 Exhibit 7 - Replacement for Dkt. 205-17, # 8 Exhibit 8 - Replacement for Dkt. 205-18, # 9 Exhibit 9 - Replacement for Dkt. 205-19, # 10 Exhibit 10 - Replacement for Dkt. 205-15, # 11 Exhibit 11 - Replacement for Dkt. 205-21)(Gardner, Melissa) (Filed on 10/18/2016) Modified on 10/19/2016 (kcS, COURT STAFF).

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Michael W. Sobol (State Bar No. 194857)
[e-mail]
David T. Rudolph (State Bar No. 233457)
[e-mail]
Melissa Gardner (State Bar No. 289096)
[e-mail]
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
275 Battery Street, 29th Floor
San Francisco, CA 94111-3339
Telephone: [phone]
Facsimile: 415.956.1008

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Hank Bates (State Bar No. 167688)
[e-mail]
Allen Carney
[e-mail]
David Slade
[e-mail]
CARNEY BATES & PULLIAM, PLLC
2800 Cantrell Road, Suite 510
Little Rock, AR 72202
Telephone: [phone]
Facsimile: 501.312.8505

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Attorneys for Plaintiffs and the Class

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MATTHEW CAMPBELL and MICHAEL
HURLEY, on behalf of themselves and all
others similarly situated,

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Plaintiffs,

Case No. C 13-05996 PJH (SK)
PLAINTIFFS’ NOTICE OF REFILING RE
MOTIONS TO COMPEL DISCOVERY
AND SUPPORTING DOCUMENTS FILED
UNDER SEAL

v.
FACEBOOK, INC.,

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Defendant.

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1324978.1

NOTICE OF RE-FILING RE ORDER
ON ADMIN. MOTION TO SEAL

C 13-05996 PJH (SK)

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Pursuant to the Court’s order on October 4, 2016 Denying Motions to Compel and

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Granting Motions To File Under Seal (Dkt. 218), Plaintiffs file replacement versions of the

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following briefs and exhibits: (1) Plaintiffs’ Motion to Compel Production of Source Code; (2)

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Plaintiffs’ Motion to Compel Production of Configuration Tables; (3) Plaintiffs’ Motion to

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Compel Production of Documents; (4) the August 1, 2016 Declaration of Dr. Jennifer Golbeck in

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Support of Plaintiffs’ Motion to Compel Production of Configuration Tables (“Golbeck

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Declaration”); and (5) Exhibits 5, 7-9, and 11-12 to the Declaration of David T. Rudolph in

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Support of Plaintiffs’ Motions to Compel Discovery (“Rudolph Declaration”).

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The Court ordered that “within two weeks of this order, plaintiffs shall re-file their motion

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papers in accordance with the more narrow redactions set forth in Facebook’s declaration

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supporting plaintiffs’ motion to file under seal.” Accordingly, this filing contains replacement

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versions of the following documents, with limited redactions consistent with the Court’s order.

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Attached as Exhibit 1 is a true and correct copy of a redacted version of Plaintiffs’ Motion

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to Compel Production of Source Code, originally filed under seal at Dkt. 205-4; and with

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redactions at Dkt. 206.

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Attached as Exhibit 2 is a true and correct copy of a redacted version of Plaintiffs’ Motion

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to Compel Production of Configuration Tables, originally filed under seal at Dkt. 205-6; and with

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redactions at Dkt. 207.

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Attached as Exhibit 3 is a true and correct copy of a redacted version of Plaintiffs’ Motion

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to Compel Production of Documents, originally filed under seal at Dkt. 205-8, and with

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redactions at Dkt. 208.

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Attached as Exhibit 4 is a true and correct copy of a redacted version of the Golbeck
Declaration, originally filed under seal at Dkt. 205-10; and with redactions at Dkt. 207-2.

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Attached as Exhibit 5 is a true and correct copy of a redacted version of Exhibit 1 to the
Rudolph Declaration, originally filed under seal at Dkt. 205-12; and with redactions at Dkt. 209-1.

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Attached as Exhibit 6 is a true and correct copy of a redacted version of Exhibit 5 to the
Rudolph Declaration, originally filed under seal in its entirety, at Dkt. 205-16.

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1324978.1

-1-

NOTICE OF RE-FILING RE ORDER
ON ADMIN. MOTION TO SEAL

C 13-05996 PJH (SK)

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Attached as Exhibit 7 is a true and correct copy of a redacted version of Exhibit 7 to the
Rudolph Declaration, originally filed under seal in its entirety, at Dkt. 205-17.

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Attached as Exhibit 8 is a true and correct copy of a redacted version of Exhibit 8 to the
Rudolph Declaration, originally filed under seal in its entirety, at Dkt. 205-18.

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Attached as Exhibit 9 is a true and correct copy of an unredacted version of Exhibit 9 to
the Rudolph Declaration, originally filed under seal in its entirety, at Dkt. 205-19.

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Attached as Exhibit 10 is a true and correct copy of a redacted version of Exhibit 11 to the

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Rudolph Declaration, originally filed under seal at Dkt. 205-15; and with redactions at Dkt. 209-

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11.

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Attached as Exhibit 11 is a true and correct copy of a redacted version of Exhibit 12 to the
Rudolph Declaration, originally filed under seal in its entirety, at Dkt. 205-21.

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Dated: October 18, 2016

Respectfully Submitted,

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Lieff Cabraser Heimann & Bernstein, LLP

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By:

/s/ Melissa Gardner
Melissa Gardner

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LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
275 Battery Street, 29th Floor
San Francisco, CA 94111-3339
Telephone: [phone]
Facsimile: 415.956.1008

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Attorneys for Plaintiffs and the Class

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1324978.1

-2-

NOTICE OF RE-FILING RE ORDER
ON ADMIN. MOTION TO SEAL

C 13-05996 PJH (SK)