Reply Declaration of Goolam Monsoor in Support of Plaintiff's Request for Rule 4(f)(3) Order — Children's Health Defense v. Facebook, Inc. (Dkt. 45.1)

Summary

In this reply declaration, Goolam Monsoor states that the declarant is a private process server contracted by ASAP Legal in Paris, France, retained by plaintiff's counsel to serve English and French documents on defendant Science Feedback. On September 22, 2020, the declarant was told that Emmanuel Vincent, the founder and president of Science Feedback, was no longer at the address on file, was given a new address, and met Vincent there at 14:30. Vincent refused to sign the waiver of service of summons, said the documents had already been received by mail, and said a lawyer had to be consulted first. Vincent signed a writing acknowledging receipt of documents. The declaration states it was executed in Paris, France on September 24, 2020.

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Case 3:20-cv-05787-SI Document 45-1 Filed 10/01/20 Page 1 of 4

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,
Case No. 20-cv-05787-SI

Plaintiff,
y REPLY DECLARATION OF GOOLAM
, MONSOOR IN SUPPORT OF
PLAINIIFF’S REQUEST FOR RULE
FACEBOOK, INC., et al., , 4(F)\(3) ORDER

Defendants.

GOOLAM MONSOOR REPLY {
DECLARATION RE: RULE 4(f)(3) ORDER
, CHD »y. Facebook et al.; Case No. 3:20-cv-05787-SK

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Case 3:20-cv-05787-SI Document 45-1 Filed 10/01/20 Page 2 of 4

DECLARATION OF GOOLAM MONSOOR

I, Goolam Monsoor, declare as follows:

1. | am a private process server contracted by ASAP Legal-in Paris, France. | am
over the age of 18, and I am not a party to this action. I was retained by plaintiff’s counsel to
serve the English and French documents referenced in my September 22, 2020 certificate of
service on defendant Science Feedback in this action. 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.

Pa On Tuesday, September 22, 2020, at 13:00 p.m., I arrived at the Science
Feedback organization address on file, at 16, rue Cécile Furtado Heine -75014 Paris, France.
There I was informed by another occupant that Mr. Emmanuel Vincent, the founder and
president of Science Feedback, is no longer at this address. I then found on the internet a
mobile phone number for Mr. Vincent of 06 07 73 52 55. I called that number and explained to
the male individual who answered the phone that I needed to deliver a “letter” to Science
Feedback. He informed me that he was no longer at the 16, rue Cécile Furtado Heine address.
Instead, the male individual provided me with a new address, which is: 7, rue de Tocqueville
75017 Paris, France. I then made an appointment to meet him there at 14:30 p.m. that same
day.

4. On information and belief, this same address -- 7, rue de Tocqueville 75017
Paris, France — is the address of Mr. Vincent. Science Feedback does not have either a
publicly-listed agent to receive process or an organizational email address.

GOOLAM MONSOOR REPLY?

DECLARATION RE: RULE 4(f)(3) ORDER
CHD v. Facebook et al.; Case No. 3:20-cv-05787-SK
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Case 3:20-cv-05787-SI Document 45-1 Filed 10/01/20 Page 3 of 4

5. At 14:30 p.m., September 22, 2020, I arrived at the address 7-9 rue de
Tocqueville -75017 Paris. As I could not gain access to the building, I dialed the mobile phone
number, and informed the male individual who answered (whose voice I recognized from
earlier in the day) that I was waiting in the street in front of the main gate.

6. A few minutes later, a male individual opened the door, and I explained that I
had a number of documents to deliver to him, including a waiver of the service of summons
which he could sign. He refused o sign the waiver form. Then I showed him the complete
package of documents I had to deliver to him. He said that he had already received those
documents by mail at the following address: 65 Avenue Philippe Auguste, 75011 PARIS.

7. At some point in our conversation, the male individual introduced himself to me
as Emmanuel Vincent, the president of Science Feedback.

8. I asked Mr. Vincent if he had received by mail the same documents bearing the
caption United States District Court for the Northen District of California in the case of
Children’s Health Defense, plaintiff, vs. Facebook, Inc. et al.., defendants. He responded “yes.”

9. Mr. Vincent told me that he had to consult his lawyer before receiving any of my
documents. He refused to let me take a photograph to show that I was present with him giving
him the documents, but he authorized me to take photographs of the documents in the
courtyard of his building.

10. Mr. Vincent also signed a writing indicating that “J’ai bien regu les documents de
la part de Monsieur Monsoor,” which translates as “I received documents from Mr. Monsoor.”

GOOLAM MONSOOR REPLY3

DECLARATION RE: RULE 4(f)(3) ORDER
} CHD vy. Facebook et al.; Case No. 3:20-ev-05787-SK
oOo ND nA FP WN KF DOD OO Wn DH HBR W NY YK OS

Case 3:20-cv-05787-SI Document 45-1 Filed 10/01/20 Page 4 of 4

I declare under penalty of perjury under the laws of the France that the foregoing is true
and correct to the best of my knowledge and that this declaration was executed in

Paris, France on September 24, 2020.

GOOLAM MONSOOR

GOOLAM MONSOOR REPLY4
DECLARATION RE: RULE 4(f)(3) ORDER
CHD vy. Facebook et al.; Case No. 3:20-cev-05787-SK


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