Complaint - CHD v. Facebook et al. (2020-11-13)

Summary

Declaration of Rita Shreffler, Director of Communications for Children's Health Defense, 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, filed 11/13/20 as Document 64-1 in support of CHD's Verified First Amended Complaint. Shreffler states that Exhibit A is a letter dated March 4, 2019 from Ms. Lyn Redwood, President, Children's Health Defense, to Mr. Mark Zuckerberg of Facebook. She states that she accessed CHD's Facebook page from November 3 through 7, 2020, and that Exhibit B contains copies of fifteen CHD articles posted between about May 15, 2019 and September 28, 2020, with the fact-check articles Facebook later attached to them and rebuttal material. The declaration is dated November 13, 2020, executed in Nixa, Missouri; its signature line is blank in this copy.

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RITA SHREFFLER DECLARATION RE:
VERIFIED FIRST AMENDED COMPLAINT
CHD v. Facebook et al.; Case No. 3:20-cv-05787-Si
1
ROGER I. TEICH
California State Bar No. 147076
290 Nevada Street
San Francisco, CA 94110
Telephone:  (415) 948-0045
E-Mail Address:  rteich@juno.com

ROBERT F. KENNEDY, JR.
MARY HOLLAND
Children’s Health Defense
1227 North Peachtree Parkway, Suite 202
Peachtree City, GA 30269
Telephone:  (917) 743-3868
E-Mail Address:  mary.holland@childrenshealthdefense.org
(Subject to pro hac vice admission)

Attorneys for Plaintiff
CHILDREN’S HEALTH DEFENSE

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

CHILDREN’S HEALTH DEFENSE,

Plaintiff,

v.

FACEBOOK, INC., et al., ,

Defendants.

Case No. 20-cv-05787-SI

DECLARATION OF RITA
SHREFFLER

Case 3:20-cv-05787-SI   Document 64-1   Filed 11/13/20   Page 1 of 3

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RITA SHREFFLER DECLARATION RE:
VERIFIED FIRST AMENDED COMPLAINT
CHD v. Facebook et al.; Case No. 3:20-cv-05787-Si
2
DECLARATION OF RITA SHREFFLER
I, Rita Shreffler, declare as follows:
1.
I am the Director of Communications for Children’s Health Defense (“CHD”),
which is the plaintiff organization in this action, Children’s Health Defense v. Facebook, Inc.,
et al., 3:20-cv-05787-SI, currently pending in the United States District Court for the Northern
District of California. This declaration is made in support of Plaintiff CHD’s Verified First
Amended Complaint. If called as a witness, I could and would testify competently to the facts
herein, except as to those matters stated on information and belief.
2.
Attached hereto as Exhibit “A” is a true and correct copy of a 9-page letter,
dated March 4, 2019, from Ms. Lyn Redwood, RN, MSN, President, Children’s Health
Defense, to Mr. Mark Zuckerberg, Chairman and Chief Executive Officer, Facebook Inc., 1
Hacker Way, Menlo Park, California 94025.
3.
On November 3 through 7, 2020, I accessed CHD’s Facebook page at the
following address: https://www.facebook.com/ChildrensHealthDefense/
4.
Attached hereto as Exhibit “B” are true and correct screenshot or print-out
copies of fifteen CHD articles which CHD posted to its Facebook page at the web address
referenced in Paragraph 3, on various dates from on or about May 15, 2019 through September
28, 2020. Also attached (as applicable) are the corresponding Facebook “fact-check” articles
which Facebook posted to CHD’s Facebook page at some date known with certainty only by
Facebook, usually within several days, but in some cases weeks, after each of those CHD
articles appeared. Also attached are true and correct copies of the rebuttal article by Dr. Brian
Case 3:20-cv-05787-SI   Document 64-1   Filed 11/13/20   Page 2 of 3

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RITA SHREFFLER DECLARATION RE:
VERIFIED FIRST AMENDED COMPLAINT
CHD v. Facebook et al.; Case No. 3:20-cv-05787-Si
3
Hooker which CHD posted to its Facebook page, and the Facebook appeal letter of Dr.
Elizabeth Mumper.
I declare under penalty of perjury under the laws of the United States that the foregoing
is true and correct to the best of my knowledge and that this declaration was executed in
Nixa, Missouri, on November 13, 2020.

_______________________

RITA SHREFFLER

Communications Director
Children’s Health Defense

Case 3:20-cv-05787-SI   Document 64-1   Filed 11/13/20   Page 3 of 3

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