Case3:14-cv-02323-WHA Document84 Filed02/02/15 Page1 of 2

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Judith B. Jennison, Bar No. 165929

JJennison@perkinscoie.com
PERKINS COIE LLP
1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Telephone: 206.359.8000
Facsimile: 206.359.9000
Attorneys for Plaintiff
Facebook, Inc.

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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FACEBOOK, INC.,

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Case No. 3:14-cv-02323

Plaintiff,

DECLARATION OF JUDITH B.
JENNISON IN SUPPORT OF FACEBOOK,
INC.S REPLY IN SUPPORT OF
DAMAGES FOR DEFAULT JUDGMENT

v.
MARTIN GRUNIN,

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Defendant.

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I, Judith B. Jennison, declare as follows:

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I am an attorney admitted to practice before this Court and I am a partner with the

law firm of Perkins Coie LLP, counsel of record for Facebook, Inc. in this action. I have personal
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knowledge of the facts set forth in this declaration unless otherwise indicated and am competent

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to testify thereto.

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2.

Attached as Exhibit A is a true and correct copy of a November 21, 2014 post by a

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user identified as mGrunin on www.reddit.com, an information and idea sharing website. The

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post has been redacted to obscure profanity and other personal details that are not relevant to the

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issues before the Court, but the complete version is available at www.reddit.com/user/mgrunin.

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-1LEGAL124923548.1

DECLARATION OF JUDITH B. JENNISON ISO

FACEBOOKS REPLY ISO DAMAGES FOR
DEFAULT JUDGMENT
Case No. 14-cv-02323

Case3:14-cv-02323-WHA Document84 Filed02/02/15 Page2 of 2

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3.

The post recounts various reasons why Mr. Grunins relationship with his

girlfriend failed, including secret trips to Atlantic City with another woman and to an Adult
Entertainment Club (where he claims to have spent more than $1,200 purchasing lap dances from

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an entertainer).
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4.

I believe that the mGrunin who composed this post is Martin Grunin, the

defendant in this action. Among other things, one year ago mGrunin posted a link to a picture

of defendant Grunin. A true and correct copy of the Reddit page containing mGrunins post and

the picture on the linked webpage are attached hereto as Exhibit B. In addition, in another Reddit

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post mGrunin describes his job as a derivatives trader, which is an occupation defendant
Grunin has claimed in prior articles and posts. Also, defendant Grunin has used the username

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mGrunin on other online accounts, such as his Instagram account, and he has sent email to my
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firm from martin@mgrunin.com.

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I declare under penalty of perjury under the laws of the United States that

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the foregoing is true and correct.

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DATED this 2nd day of February, 2015, at Seattle, Washington.

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By:

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/s/ Judith B. Jennison

Judith B. Jennison, Bar No. 165929
JJennison@perkinscoie.com

Attorneys for Plaintiff

Facebook, Inc.

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-2LEGAL124923548.1

DECLARATION OF JUDITH B. JENNISON ISO

FACEBOOKS REPLY ISO DAMAGES FOR
DEFAULT JUDGMENT
Case No. 14-cv-02323

Case3:14-cv-02323-WHA Document84-1 Filed02/02/15 Page1 of 5

EXHIBIT A

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EXHIBIT B

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Reddit User mGrunins submitted posts. The Got bitcoins? post is a link to a picture
uploaded at http://i.imgur.com/e6HovYk.png (see red circled link below).

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http://i.imgur.com/e6HovYk.png

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