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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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: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Objector Anna St. John

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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,

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v.

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FACEBOOK INC.,

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Defendant.

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ANNA ST. JOHN,
Objector.

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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

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I, Anna St. John, declare as follows:

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1. I have personal knowledge of the facts set forth herein and, if called as witness, could and

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would testify competently thereto.

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2. My full legal name is Anna Elizabeth Wagner St. John. My business address is Competitive

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Enterprise Institute, 1310 L Street NW, 7th Floor, Washington, DC 20005. My telephone number is

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[phone]. My email address is [e-mail].

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3. I am a natural-person Facebook user located in the United States.

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4. On multiple occasions from December 30, 2011 to March 1, 2017, including on or about

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June 4, 2012, August 5, 2012, November 21, 2012, June 24, 2015, and September 6, 2015, I sent or

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received private messages on Facebook to or from another Facebook user that included a URL in its

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content and from which Facebook generated a URL attachment.

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5. I am not a director, officer, agent, or employee of Facebook or its subsidiaries and affiliated

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companies. I am not a member of the Court’s immediate family or the Court staff, nor an immediate

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family member or staff member of any appellate court to which this matter may eventually be assigned.

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6. I have engaged my colleagues at the Competitive Enterprise Institute’s Center for Class

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Action Fairness (“CCAF”) to represent me in this matter. Attorneys who assisted or had other

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involvement with this objection are Theodore H. Frank, Melissa A. Holyoak, Adam E. Schulman, M.

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Frank Bednarz, and William I. Chamberlain. I intend to appear through counsel at the fairness hearing

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currently scheduled for August 9, 2017.

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7. I bring this objection in good faith to prevent approval of an unfair settlement. Unlike

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many objectors who attempt or threaten to disrupt a settlement unless plaintiffs’ attorneys buy them

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off with a share of attorneys’ fees, CCAF does not engage in quid pro quo settlements and will not

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withdraw an objection or appeal in exchange for payment.

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8. Thus, if contrary to CCAF’s practices and recommendation, I agree to withdraw my

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objection or any subsequent appeal for a payment by plaintiffs’ attorneys or the defendant paid to me

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or any person or entity related to me in any way without court approval, I hereby irrevocably waive

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4:13-cv-05996-PJH
DECLARATION OF ANNA ST. JOHN

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any and all defenses to a motion seeking disgorgement to the class of any and all funds paid in

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exchange for dismissing my appeal. In addition, if this Court has any skepticism about my motives, I

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am happy to stipulate to an injunction forbidding me from seeking compensation for settling my

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objection at any stage without court approval.

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9. The specific grounds of my objection are identified in the memorandum to be filed by my

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attorney contemporaneously with this declaration.

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I declare under penalty of perjury under the laws of the United States of America that the foregoing

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is true and correct.

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Executed on June 26, 2017, in New Orleans, Louisiana.

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Anna St. John

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4:13-cv-05996-PJH
DECLARATION OF ANNA ST. JOHN

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