facebook v grunin pg1 of 25 exhibit a archive

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28LEGAL123360242.1 -1- DECLARATION OF JUDITH B. JENNISON

IN OPPOSITION TO MOTION TO SET ASIDE DEFAULT

Case No. 14-cv-02323-CRB

Judith B. Jennison, Bar No. [email protected] COIE LLP1201 Third Avenue, Suite 4900Seattle, WA 98101-3099Telephone: 206.359.8000Facsimile: 206.359.9000

Attorneys for PlaintiffFacebook, Inc.

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

FACEBOOK, INC.,

Plaintiff,

v.

MARTIN GRUNIN,

Defendant.

Case No. 3:14-cv-02323-CRB

DECLARATION OF JUDITH B. JENNISON IN OPPOSITION TO MOTION TO SET ASIDE DEFAULT

Date: October 10, 2014Time: 10:00 a.m.Judge: Hon. Charles R. Breyer

I, Judith B. Jennison, declare as follows:

1. 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

knowledge of the facts set forth in this declaration unless otherwise indicated and am competent

to testify thereto.

2. Attached as Exhibit A is a true and correct copy of an article entitled SFC Senior

Already a Financial Trader. This article was previously available at

http://sfctoday.com/news/1025-sfc-senior-already-a-financial-trader.html, and is now archived

Case3:14-cv-02323-CRB Document48 Filed09/02/14 Page1 of 3

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and available at https://web.archive.org/web/20131223132842/http://sfctoday.com/news/1025-

sfc-senior-already-a-financial-trader.html.

3. Attached as Exhibit B is a true and correct copy of a post by mGrunin made on a

web forum called WickedFire. The post is available at http://www.wickedfire.com/shooting-

shit/86095-post-pics-your-ride-9.html. I am informed and believe that mGrunin is the

defendant in this action.

4. Attached as Exhibit C is a true and correct copy of an Instagram post by

mgrunin displaying his Rolex watch. The screenshot was taken by an employee of Perkins

Coie on May 8, 2014.

5. Attached as Exhibit D is a true and correct copy of two Instagram posts by

mgrunin displaying his Audi R8. The screenshot was taken by an employee of Perkins Coie on

May 8, 2014.

6. Attached as Exhibit E is a true and correct copy of an Instagram post by mgrunin

displaying his BMW. The screenshot was taken by an employee of Perkins Coie on May 8, 2014.

7. Attached as Exhibit F is a true and correct copy of a series of Instagram posts by

mgrunin displaying his boat. The screenshot was taken by an employee of Perkins Coie on

May 8, 2014.

8. Attached as Exhibit G is a true and correct copy of an Instagram post by

mgrunin made displaying his vacation to Cancun. The screenshot was taken by an employee of

Perkins Coie on May 8, 2014.

9. Attached as Exhibit H is a true and correct copy of a screen shot of a YouTube

video that appears to have been posted by Brian Robert Costello. The video can be found at

https://www.youtube.com/watch?v=zL7DHYBwOHk. The video instructs viewers on how to get


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out of speeding tickets by denying the authority of the police and the applicability and existence

of the law.

10. Attached as Exhibit I is a true and correct copy of a screen shot of a YouTube

video and comments that appear to have been posted by Brian Robert Costello. The video can be

found at https://www.youtube.com/watch?v=RU5FUYNn5XU. The video instructs viewers,

among other things, that attorneys are a fraud.

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

foregoing is true and correct.

DATED this 2nd day of September, 2014, at Seattle, Washington.

By: /s/ Judith B. JennisonJudith B. Jennison, Bar No. [email protected]

Attorneys for PlaintiffFacebook, Inc.


EXHIBIT A

Case3:14-cv-02323-CRB Document48-1 Filed09/02/14 Page1 of 22

7/29/2014 SFC senior already a financial trader

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SFC SENIOR ALREADY A FINANCIAL TRADERWRITTEN BY JOSEPH MATOS ON 03 MAY 2013. POSTED IN NEWS

SFC senior Martin Grunin says he is already a financial trader who is playing the markets for big stakes -- hundreds of thousands of dollars.

Grunin, a Communication Arts major who alsoplays for the SFC tennis team, said: "I want to be abillionaire one day."

Grunin said he had a mentor for three monthswhen he started trading stock markets and optionsbut that he learned very quickly and was soon ableto go out on his own.

"I'm only trading about $140,000 to $150,000 -- Ican't dedicate myself to it as much with tennis andschool," said Grunin.

He continued: "I trade every single hour. You canlose money instantly. One minute can sway moneyand it is too risky when I'm preoccupied. Over thesummer I will go harder.

"When summer comes I'm going to double mycapital -- I trade as risky as I can."

Grunin said he will need to work for a trading company eventually because he needs to take his Series 7 examinations to be authorized as a trader with theFinancial Industry Regulatory Authority (FINRA) -- and he can eventually create a hedge fund.

"If I just approach one of these big banks with my portfolio and credentials -- that will speak enough for itself," said Grunin.

"Obviously I didn't graduate from Harvard or Yale or anything but I have more experience than them. They may have gone to great schools and done terrific butthey don't have anything near the experience I have."

Grunin said that since May 2012 he has made over $200,000 in gains from the stocks and options he has been involved in.

"I paid $96,000 in commissions last year," he said.

"I drive a decent car right now and people think that my parents are extremely well off, but I actually make more than my parents put together.

"People think that my parents are loaded, they don't realize that I made this on my own ... they think maybe his parents gave him $100,000 to start off ... no oneknows that I actually started from scratch."

Grunin puts his trading news on youtube for the world to see -- watch the video at the bottom of this story. He also explains his investments on his own

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Grunin puts his trading news on youtube for the world to see -- watch the video at the bottom of this story. He also explains his investments on his ownwebsite http://www.winningportfolio.com/forum.php

Grunin said his parents know how much he makes and they're proud but his mother can be a little old fashioned and would have preferred he became a lawyeror doctor.

Grunin said: "It got to the point where she realized the type of money I was making supersedes having that title of a lawyer or a doctor."

Grunin said he pays for his college and drives a 2011 BMW 5 series.

Recently he rented a Bentley and a Lamborghini because he is in the process of deciding which one to buy. Grunin said he enjoys the cars but that: "It is simplyfor the attention. I took out a 2009 Lamborghini and then I took out a Bentley 2008 GT in February simply because I want to buy one of these cars later this year... I want to see which one I like most."

Grunin said you need stamina to be a trader.

"I sleep for four hours a night and make up for sleep on the weekends.

"Markets close at five in the evening, Asian markets open up at eight in the evening and Europeanmarkets open up at two in the morning ... if I see how European markets are trading at two in themorning, it gives me an idea of what our markets will do when they open up."

Grunin was critical of some of his fellow students for their lack of ambition.

He said that in his classes a professor will walk around the class and ask students what they plan todo after college.

He said some students say they will figure it out once college is over or say they will live with theirparents or get a job across the street.

"They don't seem to have ambition for anything ... It annoys me to some extent because theycomplain that this person has so much money etc but they don't do anything for themselves.

"Some people just want to jump into a mediocre lifestyle."

As a young child, Grunin would buy things cheap and sell them for a big profit. He got the money bugearly in life.

"Money drives me completely ... I've gotten so used just being able to go anywhere without looking at any price tags ... you realize that the only way to supportthat lifestyle is to work really hard every single day.

"If I could make the same amount of money teaching tennis then I would definitely do that ... but it isn't possible ...

"You only live once, that's the way I see it. I'm not going to sit here living a mediocre lifestyle if I'm only going to be around once."

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Copyright 2009, St. Francis College, All Rights Reserved


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EXHIBIT G


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EXHIBIT I


facebook v grunin pg1 of 25 exhibit a archive

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