Declaration of Sonal N. — Children's Health Defense v. Facebook, Inc., et al

What This Document Is

The 2-page Declaration of Sonal N. Mehta in Support of Facebook's Opposition to Plaintiff's Motion to Shorten Time, filed March 11, 2021 as attachment 1 to Doc. 77 in CHD v. Facebook, Inc., et al. (N.D. Cal.). Mehta, a WilmerHale partner representing Facebook and Zuckerberg, attests to two facts from the March 10, 2021 meet-and-confer and attaches the email exchange with the court (Exhibit A, filed as Doc. 77-2).

Factual Summary

Mehta declares: (1) she is a partner at Wilmer Cutler Pickering Hale and Dorr LLP representing Facebook and Zuckerberg in the action; (2) on March 10, 2021, during the parties' meet-and-confer in preparation for the upcoming Case Management Conference, "counsel for CHD stated that Mr. Robert F. Kennedy, Jr. is contemplating filing an original action based upon the February 10, 2021 removal of Mr. Kennedy's Instagram account"; and (3) also on March 10, CHD informed the court of its position that, if its motion to supplement were granted, that "would not moot" the defendants' pending motions to dismiss — a true and correct copy of that email is attached as Exhibit A. Executed under penalty of perjury on March 11, 2021 in Redwood City, California.

Key Facts

Filed 2021-03-11 as Doc. 77-1, supporting Facebook's opposition (Doc. 77) to CHD's motion to shorten time.
Paragraph 2 puts on the court record, under penalty of perjury, that CHD's counsel disclosed RFK Jr. was contemplating a separate original action over the February 10, 2021 Instagram account removal.
Paragraph 3 attests to CHD's emailed position that granting the supplement motion would not moot the pending motions to dismiss (email attached as Exhibit A, Doc. 77-2).

Source Caveats

None.

Date: 2021-03-11

Full text

CASE NO.: 3:20-CV-05787-SI
MEHTA DECL. ISO OPP. TO PL.’S MOT. TO
SHORTEN TIME
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SONAL N. MEHTA (SBN 222086)
 Sonal.Mehta@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
2600 El Camino Real, Suite 400
Palo Alto, California 94306
Telephone:  (650) 858-6000
Facsimile:  (650) 858-6100
ARI HOLTZBLATT (pro hac vice)
 Ari.Holtzblatt@wilmerhale.com
MOLLY M. JENNINGS (pro hac vice)
Molly.Jennings@wilmerhale.com
ALLISON SCHULTZ (pro hac vice)
Allison.Schultz@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
1875 Pennsylvania Ave NW
Washington, DC 20006
Telephone:  (202) 663-6000
Facsimile:  (202) 663-6363
Attorneys for Defendants
FACEBOOK, INC. and
MARK ZUCKERBERG
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
CHILDREN’S HEALTH DEFENSE,
Plaintiff,
v.
FACEBOOK, INC., ET AL.,
Defendants.
Case No. 3:20-cv-05787-SI
DECLARATION OF SONAL N.
MEHTA IN SUPPORT OF
FACEBOOK’S OPPOSITION TO
PLAINTIFF’S MOTION TO
SHORTEN TIME
Case 3:20-cv-05787-SI   Document 77-1   Filed 03/11/21   Page 1 of 2

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CASE NO.: 3:20-CV-05787-SI
MEHTA DECL. ISO OPP. TO PL.’S MOT. TO
SHORTEN TIME
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I, Sonal N. Mehta, declare as follows:
1.
I am a partner at Wilmer Cutler Pickering Hale and Dorr LLP. I represent Defendants
Facebook, Inc. and Mark Zuckerberg in the above-captioned action.
2.
On March 10, 2021, the parties met and conferred in preparation for the upcoming
Case Management Conference.  During that meet and confer, counsel for CHD stated that Mr.
Robert F. Kennedy, Jr. is contemplating filing an original action based upon the February 10, 2021
removal of Mr. Kennedy’s Instagram account.
3.
Also on March 10, CHD informed the Court of its position that, if its motion to
supplement were granted, that “would not moot” defendants’ pending motions to dismiss.  A true
and correct copy of that email is attached as Exhibit A.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 11th day of March, 2021 in Redwood City, California.
By:    /s/ Sonal N. Mehta
Sonal N. Mehta
Case 3:20-cv-05787-SI   Document 77-1   Filed 03/11/21   Page 2 of 2

File and source

File: gov.uscourts.cand.364478.77.1.pdf
Size: 147,845 bytes
SHA-256: bb9bb854b228575f47347c74911662bdef0a3ae20f0ce4c86317be329d92afcd
Our copy: gov.uscourts.cand.364478.77.1.pdf
Original: archive.org