Complaint - CHD v. Facebook et al. (2021-04-22)

Summary

A declaration by Roger Teich, counsel for plaintiff Children’s Health Defense, filed 03/16/21 as Document 78-1 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. It supports the parties’ stipulation and proposed order re: the April 22, 2021 hearing date and case management conference. Teich recounts that CHD filed its Second Amended Complaint on December 15, 2020 and that Facebook, Inc., Mark Zuckerberg and The Poynter Institute for Media Studies, Inc. moved to dismiss it. He states that the Clerk of the Court then wrote to all counsel about the pending motions to dismiss, after which the parties agreed to file the stipulation. He signed it in San Francisco on March 15, 2021.

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Roger Teich Declaration ISO

Stipulation and [Proposed] Order

CHD v. Facebook et al.; Case No. 3:20-cv-05787-SI
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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

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. 3:20-cv-05787-SI

ROGER TEICH DECLARATION IN
SUPPORT OF STIPULATION AND
[PROPOSED] ORDER RE: APRIL 22, 2021
HEARING DATE AND CASE
MANAGEMENT CONFERENCE

Civil L.R. 6-2

I, Roger Teich, declare as follows:
1.
I am a member of the State Bar of California and the Bar of the United States District
Court for the Northern District of California, and counsel for Plaintiff Children’s Health Defense
(“CHD”) in this action. This declaration is made in support of the Parties’ Stipulation and [Proposed]
Order re: April 22, 2021 Hearing Date and Case Management Conference. 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.
On December 15, 2020, Plaintiff CHD filed its Second Amended Complaint (“SAC”) by
written consent under Fed. R. Civ. Pro. 15(a)(2) (Dkts. 65-1 and 67). On December 21, 2020, pursuant
Case 3:20-cv-05787-SI   Document 78-1   Filed 03/16/21   Page 1 of 2

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to the stipulated briefing schedul
The Poynter Institute for Media S
68 and 69). On February 5, 2021
71). On March 3, 2021, the Cour
March 23, 2021 (Dkt. 72). On M
Dismiss (Dkts. 73 and 74). On M
Fed. R. Civ. P. 15(d) and exhibit
Motion to Shorten Time under C
could be heard with Defendants’
Defendants Facebook, Inc. and Z
(Dkt. 77).
3.
On March 12, 202
the Clerk of the Court wrote all c
Motions to Dismiss (Dkt. 68 and
22, 2021, in the interests of judic
4.
Following an exch
Parties agreed to file the Stipulat
5.
Plaintiff agrees th
I declare under penalty of
and correct to the best of my kno
California, on March 15, 2021.
2
Roge

Stipulati

CHD v. Facebook et al.
le (Dkts. 63 and 67), Defendants Facebook, Inc.,
Studies, Inc. (“Poynter”) filed their Motions to D
, Plaintiff filed its Oppositions to the Motions to
rt moved the hearing on the Motions to Dismiss
March 5, 2021, Defendants filed Replies in Suppo
March 8, 2021, Plaintiff filed its Motion to Suppl
ts thereto (docketed on ECF as “Motion to Amen
Civil L.R. 6-3 (Dkts. 75 and 76), so that its Motio
pending Motions to Dismiss on March 23, 2021
Zuckerberg filed their Opposition to CHD’s Mot
21, after exchanges with the Parties concerning t
counsel to ask if the Parties would agree to stipu
d 69) along with the Motion to Amend/Correct (D
cial economy and to allow for additional oral arg
hange of emails and “meet and confer” telephon
tion and [Proposed] Order to modify the case cal
hat its Motion to Shorten Time (Dkt. 77) is moot
f perjury under the laws of the United States tha
owledge and that this declaration was executed in

ROGER I. TEICH

Counsel for Plaintiff
Children’s Health Defense
er Teich Declaration ISO
on and [Proposed] Order
; Case No. 3:20-cv-05787-SI
, Mark Zuckerberg, and
Dismiss the SAC (Dkts.
o Dismiss (Dkts. 70 and
from March 19, 2021 to
ort of their Motions to
lement the SAC under
nd/Correct”), and its
on to Amend/Correct
1. On March 11, 2021,
tion to Shorten Time
their substantive views,
ulate to having the
Dkt. 76) heard on April
gument.
ne conference, the
lendar accordingly.
.
at the foregoing is true
n San Francisco,

Case 3:20-cv-05787-SI   Document 78-1   Filed 03/16/21   Page 2 of 2

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