Case No.: 3:20-Cv-05787-Si Declaration Of Sonal N. Mehta In Support

Date: 2020-09-09

Summary

The Declaration of Sonal N. Mehta in Support of Civil Local Rule 6-2(a) Stipulation, filed September 9, 2020 as Document 24-1 in Children's Health Defense v. Facebook, Inc., et al., Case No. 3:20-cv-05787-SI, in the U.S. District Court for the Northern District of California, San Francisco Division. Mehta, a partner at Wilmer Cutler Pickering Hale and Dorr LLP representing Facebook, Inc. and Mark Zuckerberg, describes the scheduling discussions with plaintiff's counsel. The declaration states that the time to respond to the complaint has been enlarged by stipulation to October 23, 2020. It says the defendants do not oppose the plaintiff's request for time until December 21 to respond to any Rule 12 motions, and asks that replies then be due January 21, 2021, citing the winter holidays and the number of issues. The declaration is three pages.

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Cite this document

“Case No.: 3:20-Cv-05787-Si Declaration Of Sonal N. Mehta In Support.” Original at archive.org, dated 2020-09-09. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2020-09-09-plaintiff-v-facebook-inc-et-al-3037ffbc-1/, SHA-256 3037ffbc6a8f8ab82bc9e11c606630d562a61c18ba3516cbf90fc0ca56b3f0d7.

Full text

Case 3:20-cv-05787-SI Document 24-1 Filed 09/09/20 Page 1 of 3

1 SONAL N. MEHTA (SBN 222086)
Sonal.Mehta@wilmerhale.com
2 WILMER CUTLER PICKERING
HALE AND DORR LLP
3 950 Page Mill Road
Palo Alto, California 94304
4 Telephone: (650) 858-6000
Facsimile: (650) 858-6100
5
Attorney for Defendants
6 FACEBOOK, INC. and
MARK ZUCKERBERG
7

8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
SAN FRANCISCO DIVISION
11
CHILDREN’S HEALTH DEFENSE,
12 Case No. 3:20-cv-05787-SI
Plaintiff,
13
DECLARATION OF SONAL N.
v.
14 MEHTA IN SUPPORT OF CIVIL
FACEBOOK, INC., ET AL., LOCAL RULE 6-2(A) STIPULATION
15
Defendants.
16

CASE NO.: 3:20-CV-05787-SI DECLARATION OF SONAL N. MEHTA IN SUPPORT
OF CIVIL LOCAL RULE 6-2(A) STIPULATION
Case 3:20-cv-05787-SI Document 24-1 Filed 09/09/20 Page 2 of 3

1 I, Sonal N. Mehta, declare as follows:

2 1. I am a partner at Wilmer Cutler Pickering Hale and Dorr LLP. I represent Defendants

3 Facebook, Inc. and Mark Zuckerberg in the above-captioned action.

4 2. Defendants Facebook, Inc., Mark Zuckerberg, The Poynter Institute for Media

5 Studies, Inc. and PolitiFact have sought an enlargement of time to respond to Plaintiff’s Complaint.

6 3. On September 4, I spoke with counsel for Plaintiff (and counsel for The Poynter

7 Institute for Media Studies, Inc. and PolitiFact) to request Plaintiff’s agreement for an extension of

8 time for Facebook’s response to the Complaint, which based on the alleged service date, would be

9 due on September 9. I explained that my firm had just been retained for this matter the preceding
10 evening. Counsel for Plaintiff agreed that Plaintiff would consent to an extension of time to respond
11 up to and including October 23, 2020 and requested a reciprocal extension of time up to and
12 including December 7, 2020 for Plaintiff to oppose any motion to dismiss that may be filed.
13 4. On September 8, following the Labor Day holiday weekend, I sent counsel for
14 Plaintiff a draft stipulation memorializing the October 23 and December 7 dates, and proposing that
15 Defendants file their replies in support of any Rule 12 motions by January 7, 2021 due to the
16 intervening winter holidays.
17 5. On September 9, counsel for Plaintiff requested an additional 14-day extension of
18 time for Plaintiff’s response to any Rule 12 motions, i.e., to December 21. Counsel for Plaintiff
19 proposed a schedule whereby Plaintiff’s Opposition to any Rule 12 motions be due December 21,
20 2020, and Defendants’ Replies in support of any such motions be due January 21, 2021.
21 6. The time for Defendants to answer, move, or otherwise respond to the complaint has
22 been enlarged once by stipulation filed concurrently herewith, from September 9 to October 23,
23 2020 for Defendants Facebook, Inc., Mark Zuckerberg, and The Poynter Institute for Media Studies,
24 Inc., and from September 17 to October 23, 2020 for Defendant PolitiFact.
25 7. Defendants do not oppose Plaintiff’s request for an enlargement of time to December
26 21 to respond to any Rule 12 motions.
27 8. Should the Court grant that extension, Defendants request an enlargement of time to
28 January 21, 2021 for Defendants to file replies in support of any Rule 12 motions. The additional
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CASE NO.: 3:20-CV-05787-SI DECLARATION OF SONAL N. MEHTA IN SUPPORT
OF CIVIL LOCAL RULE 6-2(A) STIPULATION
Case 3:20-cv-05787-SI Document 24-1 Filed 09/09/20 Page 3 of 3

1 time is warranted because the winter holidays fall within the time allotted for Defendants to

2 prepare their replies, and in view of the complicated subject matter of this case, the number of

3 issues in dispute, and the need to coordinate among multiple, separately represented defendants.

4 The Complaint includes several alleged constitutional and statutory violations. This proposed

5 schedule will allow the parties adequate time to study the issues and submit briefing that will aid

6 the Court in its resolution of any Rule 12 motions.

8 I declare under penalty of perjury that the foregoing is true and correct.

9 Executed on this 9th day of September 2020 in Redwood City, California.
10

11 By: /s/ Sonal N. Mehta
Sonal N. Mehta
12

28
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CASE NO.: 3:20-CV-05787-SI DECLARATION OF SONAL N. MEHTA IN SUPPORT
OF CIVIL LOCAL RULE 6-2(A) STIPULATION

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File: gov.uscourts.cand.364478.24.1.pdf
Size: 163,063 bytes
SHA-256: 3037ffbc6a8f8ab82bc9e11c606630d562a61c18ba3516cbf90fc0ca56b3f0d7
Our copy: gov.uscourts.cand.364478.24.1.pdf
Original: archive.org