Campbell et al v. Facebook Inc.

Filing 241

***SEE DOCKET ENTRY #243 FOR CORRECTED DOCUMENT*** OBJECTIONS to Proposed Settlement by Anna St. John. (Attachments: # 1 Declaration of Theodore H. Frank, # 2 Declaration of Anna St. John)(Chamberlain, William) (Filed on 6/26/2017) Modified on 6/28/2017 (cjlS, COURT STAFF).

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1 2 3 4 5 6 Theodore H. Frank (SBN 196332) William I. Chamberlain (SBN 306046) COMPETITIVE ENTERPRISE INSTITUTE CENTER FOR CLASS ACTION FAIRNESS 1310 L Street, NW, 7th Floor Washington, DC 20005 Voice: (202) 331-2263 Email: Email: Attorneys for Objector Anna St. John 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 10 11 MATTHEW CAMPBELL, MICHAEL HURLEY, on behalf of themselves and all others similarly situated, 12 Plaintiffs, 13 v. 14 FACEBOOK INC., 15 Defendant. 16 17 18 19 ANNA ST. JOHN, Objector. 20 21 22 23 24 25 26 27 Case No. 4:13-cv-5996-PJH DECLARATION OF ANNA ST. JOHN Case No. 4:13-cv-5996-PJH DECLARATION OF ANNA ST. JOHN Date: Time: Courtroom: Judge: August 9, 2017 9:00 a.m. 3, 3rd Floor Hon. Phyllis J. Hamilton 1 I, Anna St. John, declare as follows: 2 1. I have personal knowledge of the facts set forth herein and, if called as witness, could and 3 would testify competently thereto. 4 2. My full legal name is Anna Elizabeth Wagner St. John. My business address is Competitive 5 Enterprise Institute, 1310 L Street NW, 7th Floor, Washington, DC 20005. My telephone number is 6 (917) 327-2392. My email address is 7 3. I am a natural-person Facebook user located in the United States. 8 4. On multiple occasions from December 30, 2011 to March 1, 2017, including on or about 9 June 4, 2012, August 5, 2012, November 21, 2012, June 24, 2015, and September 6, 2015, I sent or 10 received private messages on Facebook to or from another Facebook user that included a URL in its 11 content and from which Facebook generated a URL attachment. 12 5. I am not a director, officer, agent, or employee of Facebook or its subsidiaries and affiliated 13 companies. I am not a member of the Court’s immediate family or the Court staff, nor an immediate 14 family member or staff member of any appellate court to which this matter may eventually be assigned. 15 6. I have engaged my colleagues at the Competitive Enterprise Institute’s Center for Class 16 Action Fairness (“CCAF”) to represent me in this matter. Attorneys who assisted or had other 17 involvement with this objection are Theodore H. Frank, Melissa A. Holyoak, Adam E. Schulman, M. 18 Frank Bednarz, and William I. Chamberlain. I intend to appear through counsel at the fairness hearing 19 currently scheduled for August 9, 2017. 20 7. I bring this objection in good faith to prevent approval of an unfair settlement. Unlike 21 many objectors who attempt or threaten to disrupt a settlement unless plaintiffs’ attorneys buy them 22 off with a share of attorneys’ fees, CCAF does not engage in quid pro quo settlements and will not 23 withdraw an objection or appeal in exchange for payment. 24 8. Thus, if contrary to CCAF’s practices and recommendation, I agree to withdraw my 25 objection or any subsequent appeal for a payment by plaintiffs’ attorneys or the defendant paid to me 26 or any person or entity related to me in any way without court approval, I hereby irrevocably waive 27 4:13-cv-05996-PJH DECLARATION OF ANNA ST. JOHN 2 1 any and all defenses to a motion seeking disgorgement to the class of any and all funds paid in 2 exchange for dismissing my appeal. In addition, if this Court has any skepticism about my motives, I 3 am happy to stipulate to an injunction forbidding me from seeking compensation for settling my 4 objection at any stage without court approval. 5 9. The specific grounds of my objection are identified in the memorandum to be filed by my 6 attorney contemporaneously with this declaration. 7 I declare under penalty of perjury under the laws of the United States of America that the foregoing 8 is true and correct. 9 10 Executed on June 26, 2017, in New Orleans, Louisiana. 11 12 Anna St. John 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 4:13-cv-05996-PJH DECLARATION OF ANNA ST. JOHN 3

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