Campbell et al v. Facebook Inc.
Filing
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RESPONSE (re 29 MOTION to Dismiss Consolidated Amended Complaint ) filed byMatthew Campbell, Michael Hurley, David Shadpour. (Attachments: # 1 Declaration of Michael W. Sobol, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D)(Sobol, Michael) (Filed on 7/30/2014)
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Michael W. Sobol (State Bar No. 194857)
msobol@lchb.com
Melissa Gardner (State Bar No. 289096)
mgardner@lchb.com
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
275 Battery Street, 29th Floor
San Francisco, CA 94111-3339
Telephone: 415.956.1000
Facsimile: 415.956.1008
Rachel Geman
rgeman@lchb.com
Nicholas Diamand
ndiamand@lchb.com
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
250 Hudson Street, 8th Floor
New York, NY 10013-1413
Telephone: 212.355.9500
Facsimile: 212.355.9592
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Patrick V. Dahlstrom
pdahlstrom@pomlaw.com
POMERANTZ, LLP
10 S. La Salle Street, Suite 3505
Chicago, Illinois 60603
Telephone: 312.377.1181
Facsimile: 312.377.1184
Hank Bates (State Bar No. 167688)
hbates@cbplaw.com
Allen Carney
acarney@cbplaw.com
David Slade
dslade@cbplaw.com
CARNEY BATES & PULLIAM, PLLC
11311 Arcade Drive
Little Rock, AR 72212
Telephone: 501.312.8500
Facsimile: 501.312.8505
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Jeremy A. Lieberman
Lesley F. Portnoy
info@pomlaw.com
POMERANTZ, LLP
600 Third Avenue, 20th Floor
New York, New York 10016
Telephone: 212.661.1100
Facsimile: 212.661.8665
Attorneys for Plaintiffs and the Proposed 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, and DAVID SHADPOUR, on
behalf of themselves and all others
similarly situated,
DECLARATION OF MICHAEL W.
SOBOL IN SUPPORT OF PLAINTIFFS’
OPPOSITION TO MOTION TO DISMISS
Plaintiffs,
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v.
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FACEBOOK, INC.,
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Case No. C 13-05996 PJH
HEARING
Date:
September 17, 2014
Time:
9:00 a.m.
Place:
Courtroom 3, 3rd Floor
The Honorable Phyllis J. Hamilton
Defendant.
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DECLARATION OF MICHAEL W. SOBOL
CASE NO. C 13-05996 PJH
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I, Michael W. Sobol, declare as follows:
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1.
I am a partner of the law firm Lieff Cabraser Heimann & Bernstein, LLP,
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representing the Plaintiffs in the above-entitled action. I am a member in good standing of the
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State Bar of California. I have personal knowledge of the statements contained in this
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Declaration and if called to testify, I could and would testify competently to them.
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2.
Attached as Exhibit A is a true and correct copy of Facebook’s current Statement
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of Rights and Responsibilities, dated November 15, 2013, the text of which is available online at
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https://www.facebook.com/legal/terms.
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3.
Attached as Exhibit B is a true and correct copy of Facebook’s current Data Use
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Policy, dated November 15, 2013, the text of which is available online at
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https://www.facebook.com/about/privacy/.
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4.
Attached as Exhibit C is a true and correct copy of Senate Report No. 99-541,
dated October 17, 1986.
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Attached as Exhibit D is a true and correct copy of a Memorandum of Decision
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and Order on Defendant’s Motion to Dismiss, in Marquis v. Google, No. 11-2808-BLS1 in
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Massachusetts Superior Court, dated January 17, 2012.
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6.
Persons under my direction conducted a reasonable search and were unable to
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verify the authenticity of the documents submitted as Exhibits B, C, E, and F to the Declaration of
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Jeremy Jordan submitted in support of Defendant’s Motion to Dismiss.
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I declare under penalty of perjury that the foregoing is true and correct and that this
Declaration was signed in San Francisco, California, on July 30, 2014.
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Michael W. Sobol
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-1-
DECLARATION OF MICHAEL W. SOBOL
CASE NO. C 13-05996 PJH
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