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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
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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