Rita Shreffler Declaration Re
Summary
The Declaration of Rita Shreffler, Director of Communications for plaintiff Children's Health Defense, filed July 27, 2021 as Document 111-1 in Children's Health Defense v. Facebook, Inc., et al., Case No. 3:20-cv-05787-SI, in the United States District Court for the Northern District of California. It supports the plaintiff's Motion to Stay Judgment as to Defendant Science Feedback, or for an indicative ruling on the timeliness of June 24, 2021 service. The declaration lists payments for certified French translations and process service, including a combined translation expenditure of $13,501.54, and states that CHD has spent over $17,000 in its efforts to serve Science Feedback. It describes attached Exhibits A, B, C and D, including French Ministry of Justice documents, their English translation, an index of translated documents and a DHL waybill.
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Case 3:20-cv-05787-SI Document 111-1 Filed 07/27/21 Page 1 of 3
1 ROGER I. TEICH
California State Bar No. 147076
2 290 Nevada Street
San Francisco, CA 94110
3 Telephone: (415) 948-0045
4 E-Mail Address: rteich@juno.com
5 ROBERT F. KENNEDY, JR.
MARY HOLLAND
6 Children’s Health Defense
1227 North Peachtree Parkway, Suite 202
7 Peachtree City, GA 30269
8 Telephone: (917) 743-3868
E-Mail Address: mary.holland@childrenshealthdefense.org
9 (Subject to pro hac vice admission)
10 Attorneys for Plaintiff
CHILDREN’S HEALTH DEFENSE
11
12 UNITED STATES DISTRICT COURT
13 NORTHERN DISTRICT OF CALIFORNIA
14 SAN FRANCISCO DIVISION
15
16
17 CHILDREN’S HEALTH DEFENSE,
18
Plaintiff,
Case No. 20-cv-05787-SI
19
v.
20 DECLARATION OF RITA
SHREFFLER
21 FACEBOOK, INC., et al.,
22
Defendants.
23
24
25
26
27
28
1 RITA SHREFFLER DECLARATION RE:
MOTION TO STAY JUDGMENT FOR
SCIENCE FEEDBACK, OR FOR INDICATIVE RULING
CHD v. Facebook et al.; Case No. 3:20-cv-05787-Si
Case 3:20-cv-05787-SI Document 111-1 Filed 07/27/21 Page 2 of 3
1 DECLARATION OF RITA SHREFFLER
2 I, Rita Shreffler, declare as follows:
3 1. I am the Director of Communications for Children’s Health Defense (“CHD”),
4 which is the plaintiff organization in this action, Children’s Health Defense v. Facebook, Inc.,
5 et al., 3:20-cv-05787-SI. This declaration is made in support of Plaintiff CHD’s Motion to Stay
6 Judgment as to Defendant Science Feedback on good cause to extend time for foreign service,
7 or for indicative ruling as to timeliness of June 24, 2021 service. If called as a witness, I could
8 and would testify competently to the facts herein, except as to those matters stated on
9 information and belief.
10 2. I am informed by Heidi Kidd, CHD’s Treasurer, and thereupon believe that,
11 based on Mr. Kidd’s review of CHD’s pertinent bank records, CHD has paid the following
12 monies in relation to service of process on the French corporate defendant, Science Feedback:
13 On October 31, 2020, CHD paid Ms. Breton $3,077.44 for her certified translation services. In
14 September through October, 2020, CHD also paid ASAP Process Servers $2,428.13 for its
15 efforts to serve all defendants, including its multiple efforts to serve Mr. Vincent abroad. I am
16 informed by Mr. Teich, co-counsel for CHD in this action that, on or about December 20,
17 2021, he received from Ms. Breton a copy of the French translation of its First Amended
18 Complaint, and request for additional payment to translate the Second Amended Complaint
19 and related documents. On January 14, 2021, CHD paid Ms. Breton an additional $9,405.30 to
20 provide a certified French translation of the SAC and Exh. “B” (Dkts. #65, 65-4.) On or about
21 January 30, 2021, CHD received from Ms. Breton a certified French translation of the SAC.
22 On or about February 21, 2021, CHD received from Ms. Breton a certified French translation
23 of the SAC Exh. B. All told, CHD engaged with Ms. Breton and/or ASAP to render French
24 translations of its Second Amended Complaint (“SAC”), SAC Exhs. “A” and “B” and eleven
25 other case-related civil filing documents, which combined total well over 400-pages of text. On
26 March 13, 2021, CHD paid ASAP Process Servers $1,589.38 for having initiated service of
27 Science Feedback under the Hague Convention, On or about July 22, 2021, CHD paid Ms.
28 Breton an additional $1,018.80 for a certified English translation of the French Ministry of the
2 RITA SHREFFLER DECLARATION RE:
MOTION TO STAY JUDGMENT FOR
SCIENCE FEEDBACK, OR FOR INDICATIVE RULING
CHD v. Facebook et al.; Case No. 3:20-cv-05787-Si
Case 3:20-cv-05787-SI Document 111-1 Filed 07/27/21 Page 3 of 3
1 Interior attestation of service and related documents, for a combined total expenditure on
2 translations of $13,501.54. Thus, CHD has spent over $17,000 to date in its efforts to serve
3 Science Feedback.
4 3. On information and belief, attached hereto as Exhibit “A” are true and correct
5 copies of selected documents which Mr. Teich received on or about July 15, 2021, from the
6 French Ministry of Justice with respect to its effort to serve Science Feedback under the Hague
7 Convention.
8 3. On information and belief, attached hereto as Exhibit “B” are true and correct
9 copies of Ms. Breton’s certified English translation of the French Ministry of Justice
10 documents referenced in Exhibit “A.”
11 4. On information and belief, attached hereto as Exhibit “C” is a true and correct
12 copy of CHD’s index of service documents for which CHD retained Ms. Breton to translate
13 from English to French.
14 5. On information and belief, attached hereto as Exhibit “D” are true and correct
15 copies of ASAP’s September 28, 2020 DHL waybill and transport label for mailed service of
16 the case-related documents to Mr. Emmanuel Vincent, Science Feedback, 7-9 rue de
17 Tocqueville, 75017 Paris France.
18 I declare under penalty of perjury under the laws of the United States that the foregoing
19 is true and correct to the best of my knowledge and that this declaration was executed in
20 Nixa, Missouri, on July 26, 2021.
21
22
23 RITA SHREFFLER
24
Communications Director
25 Children’s Health Defense
26
27
28
3 RITA SHREFFLER DECLARATION RE:
MOTION TO STAY JUDGMENT FOR
SCIENCE FEEDBACK, OR FOR INDICATIVE RULING
CHD v. Facebook et al.; Case No. 3:20-cv-05787-Si
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