Campbell et al v. Facebook Inc.

Filing 237

Motion and [Proposed] Order for Final Approval of Class Action Settlement filed by Matthew Campbell, Michael Hurley. Motion Hearing set for 8/9/2017 09:00 AM in Courtroom 3, 3rd Floor, Oakland before Hon. Phyllis J. Hamilton. Responses due by 6/26/2017. Replies due by 7/10/2017. (Attachments: # 1 Declaration of Hank Bates and Michael Sobol, and Exhibits 1-2, # 2 Proposed Order)(Sobol, Michael) (Filed on 5/26/2017) Modified on 5/30/2017 (cjlS, 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
Rachel Geman
[e-mail]
Nicholas Diamand
[e-mail]
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
250 Hudson Street, 8th Floor
New York, NY 10013-1413
Telephone: [phone]
Facsimile: 212.355.9592

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Hank Bates (State Bar No. 167688)
[e-mail]
Allen Carney
[e-mail]
David Slade
[e-mail]
CARNEY BATES & PULLIAM, PLLC
519 West 7th Street
Little Rock, AR 72201
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, MICHAEL
HURLEY, on behalf of themselves and all
others similarly situated,

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Plaintiffs,
v.
FACEBOOK, INC.,
Defendant.

Case No. 4:13-cv-05996-PJH
JOINT DECLARATION OF MICHAEL
SOBOL AND HANK BATES IN SUPPORT
OF PLAINTIFFS’ MOTION FOR FINAL
APPROVAL OF CLASS ACTION
SETTLEMENT
Date: August 9, 2017
Time: 9:00 a.m.
Judge: Hon. Phyllis J. Hamilton
Place: Courtroom 3, 3rd Floor

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DECLARATION OF M. SOBOL & H. BATES ISO
MOT. FOR FINAL APPROVAL
CASE NO. 4:13-CV-05996-PJH

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We, Michael Sobol and Hank Bates, declare as follows:

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1.

Michael Sobol is a member in good standing of the California State Bar and a

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partner in the law firm Lieff, Cabraser, Heimann & Bernstein, LLP (“LCHB”), counsel for

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Plaintiffs and the Class in this proceeding. He is the LCHB attorney principally responsible for

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overseeing LCHB’s work in this proceeding.

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2.

Hank Bates is a member in good standing of the California and Arkansas State

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Bars and a partner in the law firm Carney Bates & Pulliam PLLC (“CBP”), counsel for Plaintiffs

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and the Class in this proceeding. He is the CBP attorney principally responsible for overseeing

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CBP’s work in this proceeding.

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3.

We submit this declaration jointly in support of Plaintiffs’ Motion for Final

Approval of Class Action Settlement.

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4.

Except as otherwise noted, we have personal knowledge of the facts set forth

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herein, and if called to testify thereto, could and would do so competently, including with respect

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to the information provided regarding our respective law firms.

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5.

Consistent with the Court’s Order Granting Preliminary Approval of Class Action

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Settlement as Modified (Dkt. No 235), notice of the settlement in this Action was posted on Class

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Counsels’ websites1 on May 3, 2017.

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6.

This notice included the Court’s Order, the Settlement Agreement, and Plaintiffs’

Motion for Preliminary Approval of Class Action Settlement.

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7.

Attached hereto as Exhibit 1 are screen shots of the portions of CBP’s website

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related to notice of the settlement in this Action. These changes were implemented on May 3,

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2017 and have remained in place, to date.

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8.

Attached hereto as Exhibit 2 are screen shots of the portions of LCHB’s website

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related to notice of the settlement in this Action. These changes were implemented on May 3,

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2017 and have remained in place, to date.

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9.

In further compliance with the Court’s Order, Class Counsel will post, on their

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websites, the following documents, as soon as such documents are filed: Plaintiffs’ Motion for

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1

Respectively, www.cbplaw.com and www.lieffcabraser.com
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DECLARATION OF M. SOBOL & H. BATES ISO
MOT. FOR FINAL APPROVAL
CASE NO. 4:13-CV-05996-PJH

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Attorneys’ Fees and Incentive Awards, and any opposition or reply papers related to any motion

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identified in ¶ 7.d of the Court’s Order.

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I declare under penalty of perjury that the foregoing is true and correct. Executed this
26th day of May, 2017 in San Francisco, California.

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/s/ Michael W. Sobol
Michael W. Sobol

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I declare under penalty of perjury that the foregoing is true and correct. Executed this
26th day of May, 2017 in Little Rock, Arkansas.

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/s/ Hank Bates
Hank Bates

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DECLARATION OF M. SOBOL & H. BATES ISO
MOT. FOR FINAL APPROVAL
CASE NO. 4:13-CV-05996-PJH

EXHIBIT 1

EXHIBIT 2