Campbell et al v. Facebook Inc.

Filing 246

Supplemental Declaration of Anna St. John in Support of 243 Objection, filed byAnna St. John. (Related document(s) 243 ) (Chamberlain, William) (Filed on 8/1/2017) Modified on 8/2/2017 (vlkS, COURT STAFF).

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Theodore H. Frank (SBN 196332)
William I. Chamberlain (SBN 306046)
(Only admitted in California; practice directly
supervised by members of the D.C. Bar)
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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OAKLAND DIVISION

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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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Case No. 4:13-cv-5996-PJH
SUPPLEMENTAL DECLARATION OF
ANNA ST. JOHN
Date:
Time:
Courtroom:
Judge:

ANNA ST. JOHN,
Objector.

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Case No. 4:13-cv-5996-PJH
SUPPLEMENTAL DECLARATION OF ANNA ST. JOHN

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 June 26, 2017, I filed an objection to the proposed settlement in this matter. See Dkt.

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241.

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5. On July 10, 2017, defendant Facebook, Inc. filed a Statement in Support of Final Approval

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and Response to Objection that, inter alia, claimed I had “failed to meet [my] burden to show that [I]

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am an aggrieved class member who has standing to object to the settlement” because I had not

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attached any of my private messages that established my membership in the class. Dkt. 245 at 2 n.1

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(internal quotation marks omitted).

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6. Contemporaneously with my objection I submitted a declaration setting forth sample,

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non-exclusive dates on which I sent or received private messages on Facebook to or from another

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Facebook user that included a URL in its content and from which Facebook generated a URL

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attachment. See St. John Decl., Dkt. 241-2 ¶ 4. The preliminary approval order did not require

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objecting class members to attach any private messages to their objections. See Dkt. 235.

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7. In good faith and out of an abundance of caution, I am providing the Court with copies

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of several Facebook messages that I believe show I am a member of the class. I have redacted the

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sender/recipient’s name and any identifying information such as phone number and email address

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from these messages; however, if there is any dispute as to whether these individuals were Facebook

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users at the time the messages were sent (and there should not be), I will submit unredacted copies in

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camera for the Court’s review.

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

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8. A true and correct copy of a redacted “print to PDF” Facebook message that I sent on
June 4, 2012, is attached hereto as Exhibit 1.
9. A true and correct copy of a redacted “print to PDF” Facebook message that I received
on August 5, 2012, is attached hereto as Exhibit 2.
10. A true and correct copy of a redacted “print to PDF” Facebook message that I received
on November 21, 2012, is attached hereto as Exhibit 3.
11. A true and correct copy of a redacted “print to PDF” Facebook message that I received
on June 24, 2015, is attached to this Declaration as Exhibit 5.
12. A true and correct copy of a redacted “print to PDF” Facebook message that I received

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on September 6, 2015, is attached to this Declaration as Exhibit 5.

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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 August 1, 2017, in New Orleans, Louisiana.

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Anna St. John

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

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CERTIFICATE OF SERVICE

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I hereby certify that, on August 1, 2017, service of this document was accomplished pursuant to the

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Court’s electronic filing procedures by filing this document through the ECF system.

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/s/ William I. Chamberlain
William I. Chamberlain

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

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EXHIBIT 1

7/31/2017

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Anna

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06/04/2012 6:46PM

Hi
-- I saw your post about looking for an
apartment in Chicago. My brother-in-law posted that
an apartment he owns in the Streeterville area of
Chicago is becoming available next month. With that
kind of timing, I figured it only made sense to send
you the info for his place. I don't know anything
beyong what's in this message, but feel free to
contact him if you're interested.
Address is 253 E. Delaware #17C,
http://www.zillow.com/homedetails/253-E-DelawarePl-APT-17C-Chicago-IL-60611/3851113_zpid/
Asking $1450/month (negotiable). Rent includes:
Heat, Water, Gas, 24hr Doorman, Indoor/heated/valet
parking available for $180/month (I think, I'll double
check on that) 2 blocks to Oak St Beach. Very close to
Michigan Ave, buses and Red Line.
contact info:
cell phone.

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It's not a furnished rental anymore.

https://facebook.com/

1 bed/1 bath in Chicago (253 E Delaware Pl
APT 17C, Chicago, IL 60611)
Zestimate® Home Value: $195,500. Furnished
rental in the quiet side of Streeterville. A block…
from Lake Shore Park, 2 Blocks from the beach
zillow.com
Thanks! Passed this info on.

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EXHIBIT 2

7/31/2017

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Anna

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4 mutual friends including
Principal at Archaeon, Architects
Lives in Cabin John, Maryland
08/05/2012 10:02PM

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Hi Anna,

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I see that we have several friends in common and
thought that you may be a fellow local small business
professional. I’m a native Washingtonian and a local
small business architectural design professional.

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Please consider friending my Facebook page, and
“like” my Archaeon, Inc., Architects Facebook page
and visit my web site.
http://www.archaeon.com
https://www.facebook.com/pages/Archaeon-IncArchitects/112696352096

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Washington DC Architect - Archaeon:
Architectural Firm: Residential, Commercia…
Maryland, Virginia,
A full service architectural firm serving
Maryland, Virginia and Washington, DC.…
Residential & commercial projects;
archaeonarchitects.com

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EXHIBIT 3

8/1/2017

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Anna

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, 61 others
11/21/2012 9:33PM

…
offering 30% off all our products beginning
November 23-26 to anyone who is willing to sign up
as a Preferred Client (a one time $20 fee that will
allow you to save 20% on all your orders once the
sale ends for a YEAR!!). Plus, if you spend $100 on
products, you get to choice one of the following
products for FREE!! I'm really trying to meet my goal
this month to become District Manager and every
little bit will help!!

Spend $100 on products, get one of the following
FREE (your choice!!)
- Awaken Sea Salt Scrub - my absolute favorite!
- RE9 Advanced Instant Lift Gel - better than Botox!
- Makeup Primer
- Sheer Glow Highlighter
- FC5 Deep Cleansing Mask
- FC5 Intense Hydration Mask
- Intelligence Rejuvenating Cream
- Daily Fiber Boost
- SeaSource Detox Spa Rescue Wash
- Re9 Men's Moisturizer
- Energy Fizz Sticks (Pomegranate or Citrus)

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The sale starts at 6am Friday, November 23 and ends
at 9pm Monday, November 26. All you have to do is
message me about your order! And don't forget to
check out our Holiday line at my website:
http://www.
.myarbonne.com
All of our products make GREAT Christmas gifts for
your loved ones. Offer them the gift of products that
are PURE. SAFE. and BENEFICIAL.
Myarbonne
.myarbonne.com
12/25/2012 9:14PM

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EXHIBIT 4

7/31/2017

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Anna

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06/24/2015 8:32AM

Hey girl, I party swapped with Kindra who sells
Jamberry, so I am hosting a show for her tomorrow
night and online... this is the link if you're interested
Hope the move is going okay, if you need
anything please let us know!!! And let's plan a play
date for July!!!
http://kindraw.jamberrynails.net/party/?
uid=d0742599-e571-47ac-afcf-09abee508091

Jamberry Nails Party:
(Hosted by

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Jamberry nail wraps offer the hottest
trend in fashion. Wrap your nails in…
over 300 different designs.
kindraw.jamberrynails.net

06/24/2015 8:21PM

, Hi! Thanks for reaching out! I'd love to get a
guest profile to check out the products. I've heard
great things but never tried any of them personally.
I'll check out the link you sent and Charles and I
would love a play date!

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06/25/2015 6:32AM

Thank you! The basics: Nutrition and personal care
products... free of harmful chemicals, formulated with
highly absorbable nutrients and made by a company
with a significant green commitment!!
Here’s my Guest Profile:
https://zenplify.biz/
13178851/GuestProfile
It takes less than 5 minutes and I’m the only person
who can see your responses. I’ll get back in touch to
go over it with you!!

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EXHIBIT 5

7/31/2017

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Anna

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But yall wil be down here for the first weekend in
June, right?!

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05/18/2015 8:33AM

Yes! Scott found us a place to live this past weekend.
We move in on June 1

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05/18/2015 2:45PM

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Wooooo!!!
06/15/2015 4:13AM

Hey! Hope all is well! Wanted to check in and see how
you were settling in in Nola?!

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09/06/2015 5:38PM

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Top 6 Wines That Pair Best With Your Child's
Crappy Behavior. Epic News for Parents.
There is a lot of science that goes behind
deciding which wine goes best with your…
chicken, seafood or steak
lifeasaramblingredhead.com dinner, but what if I
09/06/2015 8:00PM

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