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FILED
Hearing Date: No hearing scheduled 11/21/2023 9:01 AM
Location: <> IRIS Y. MARTINEZ
Judge: Calendar, 3 CIRCUIT CLERK
COOK COUNTY, IL
2018CH03868
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS Calendar, 3
COUNTY DEPARTMENT, CHANCERY DIVISION 25293977
GENERAL CHANCERY SECTION
FILED DATE: 11/21/2023 9:01 AM 2018CH03868
PEOPLE OF THE STATE OF ILLINOIS,
Plaintiff,
v. Case No. 2018 CH 03868
FACEBOOK, INC. a Delaware corporation, Honorable Allen P. Walker
SCL GROUP LIMITED, and
CAMBRIDGE ANALYTICA, LLC,
Defendants.
JOINT MOTION OF THE ILLINOIS ATTORNEY GENERAL AND FACEBOOK, INC.
TO STAY PROCEEDINGS FOR ADDITIONAL 120 DAYS
Plaintiff, THE PEOPLE OF THE STATE OF ILLINOIS, by and through the Illinois Attorney
General, and Defendant FACEBOOK, INC., 1 for their Joint Motion to Stay Proceedings for
Additional 120 Days, state as follows:
1. On August 19, 2021, the Illinois Attorney General entered his appearance in this matter
and requested that the Court stay the proceedings in order to allow the plaintiff to attempt
to resolve the plaintiff’s claims in this matter by way of a multistate investigation and
negotiation with FACEBOOK, INC.
2. On August 20, 2021, October 20, 2021, January 20, 2022, April 22, 2022, July 14, 2022,
October 7, 2022, January 17, 2023, April 17, 2023, and July 31, 2023, this Court granted
the Motion to Stay Proceedings that Plaintiff, THE PEOPLE OF THE STATE OF
ILLINOIS, filed in this matter.
1
Facebook, Inc. changed its corporate name to Meta Platforms, Inc. on October 28, 2021. For ease of
reference and consistency, the parties use “Facebook” to refer to the company.
1
3. The plaintiff and Defendant FACEBOOK, INC. continue to explore the possibility of
settlement of the claims in this matter, and the parties have made substantial progress in
FILED DATE: 11/21/2023 9:01 AM 2018CH03868
negotiating a potential resolution since August 20, 2021. More specifically, since the
Court last extended the stay in July, the parties have made important additional progress
in their negotiations. Active negotiations are ongoing.
4. The parties respectfully request a period of time during which to explore whether the
remaining issues can be agreed upon among the parties, which would resolve the
plaintiff’s claims in this matter.
5. The Cook County State’s Attorney does not oppose this motion.
WHEREFORE, the parties respectfully request that this Court grant the Joint Motion to Stay
Proceedings for Additional 120 Days.
Dated: November 21, 2023.
Respectfully submitted,
/s/ Elizabeth Blackston
Elizabeth Blackston
Assistant Attorney General
Consumer Fraud Bureau
Attorney No. 99000
KWAME RAOUL
Attorney General of Illinois
ELIZABETH BLACKSTON
Consumer Fraud Bureau, Chief
MATTHEW VAN HISE
Chief Privacy Officer
CAROLYN FRIEDMAN
2
Assistant Attorneys General
Consumer Fraud Bureau
500 South Second Street
FILED DATE: 11/21/2023 9:01 AM 2018CH03868
Springfield, IL 62701
(217)782-9021
Elizabeth.Blackston@ilag.gov
Matthew.VanHise@ilag.gov
Carolyn.Friedman@ilag.gov
Attorneys for Plaintiff People of the State of Illinois
PERKINS COIE LLP
Debra R. Bernard
dbernard@perkinscoie.com
Christopher B. Wilson
cwilson@perkinscoie.com
131 S. Dearborn Street, Suite 1700
Chicago, IL 60603-5559
Tel: 312.325.8400
Fax: 312.593.1774
Firm ID: 39225
GIBSON, DUNN & CRUTCHER, LLP
Joshua S. Lipshutz (ARDC No. 6331205)
jlipshutz@gibsondunn.com
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036
Tel: 202.955.8500
Fax: 202.530.9614
Attorneys for Defendant Facebook, Inc.
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CERTIFICATE OF SERVICE
FILED DATE: 11/21/2023 9:01 AM 2018CH03868
I, Elizabeth Blackston, an attorney, hereby certify that I caused to be served the above
and foregoing JOINT MOTION TO STAY PROCEEDINGS FOR ADDITIONAL 120
DAYS by causing a true and accurate copy of such paper to be filed and transmitted to counsel
of record for Cook County and for Defendant Facebook, Inc. via the Court’s CM/ECF electronic
filing system, on this 21st day of November, 2023.
/s/ Elizabeth Blackston
4
Preview
FILED Hearing Date: No hearing scheduled 11/21/2023 9:01 AM Location: <> IRIS Y. MARTINEZ Judge: Calendar, 3 CIRCUIT CLERK COOK COUNTY, IL 2018CH03868 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS Calendar, 3 COUNTY DEPARTMENT, CHANCERY DIVISION 25293977 GENERAL CHANCERY SECTION FILED DATE: 11/21/2023 9:01 AM 2018CH03868 PEOPLE OF THE STATE OF ILLINOIS, Plaintiff, v. Case No. 2018 CH 03868 FACEBOOK, INC. a Delaware corporation, Honorable Allen P. Walker SCL GROUP LIMITED, and CAMBRIDGE ANALYTICA, LLC, Defendants. JOINT MOTION OF THE ILLINOIS ATTORNEY GENERAL AND FACEBOOK, INC. TO STAY PROCEEDINGS FOR ADDITIONAL 120 DAYS Plaintiff, THE PEOPLE OF THE STATE OF ILLINOIS, by and through the Illinois Attorney General, and Defendant FACEBOOK, INC., 1 for their Joint Motion to Stay Proceedings for Additional 120 Days, state as follows: 1. On August 19, 2021, the Illinois Attorney General entered his appearance in this matter and requested that the Court stay the proceedings in order to allow the plaintiff to attempt to resolve the plaintiff’s claims in this matter by way of a multistate investigation and negotiation with FACEBOOK, INC. 2. On August 20, 2021, October 20, 2021, January 20, 2022, April 22, 2022, July 14, 2022, October 7, 2022, January 17, 2023, April 17, 2023, and July 31, 2023, this Court granted the Motion to Stay Proceedings that Plaintiff, THE PEOPLE OF THE STATE OF ILLINOIS, filed in this matter. 1 Facebook, Inc. changed its corporate name to Meta Platforms, Inc. on October 28, 2021. For ease of reference and consistency, the parties use “Facebook” to refer to the company. 1 3. The plaintiff and Defendant FACEBOOK, INC. continue to explore the possibility of settlement of the claims in this matter, and the parties have made substantial progress in FILED DATE: 11/21/2023 9:01 AM 2018CH03868 negotiating a potential resolution since August 20, 2021. More specifically, since the Court last extended the stay in July, the parties have made important additional progress in their negotiations. Active negotiations are ongoing. 4. The parties respectfully request a period of time during which to explore whether the remaining issues can be agreed upon among the parties, which would resolve the plaintiff’s claims in this matter. 5. The Cook County State’s Attorney does not oppose this motion. WHEREFORE, the parties respectfully request that this Court grant the Joint Motion to Stay Proceedings for Additional 120 Days. Dated: November 21, 2023. Respectfully submitted, /s/ Elizabeth Blackston Elizabeth Blackston Assistant Attorney General Consumer Fraud Bureau Attorney No. 99000 KWAME RAOUL Attorney General of Illinois ELIZABETH BLACKSTON Consumer Fraud Bureau, Chief MATTHEW VAN HISE Chief Privacy Officer CAROLYN FRIEDMAN 2 Assistant Attorneys General Consumer Fraud Bureau 500 South Second Street FILED DATE: 11/21/2023 9:01 AM 2018CH03868 Springfield, IL 62701 (217)782-9021 Elizabeth.Blackston@ilag.gov Matthew.VanHise@ilag.gov Carolyn.Friedman@ilag.gov Attorneys for Plaintiff People of the State of Illinois PERKINS COIE LLP Debra R. Bernard dbernard@perkinscoie.com Christopher B. Wilson cwilson@perkinscoie.com 131 S. Dearborn Street, Suite 1700 Chicago, IL 60603-5559 Tel: 312.325.8400 Fax: 312.593.1774 Firm ID: 39225 GIBSON, DUNN & CRUTCHER, LLP Joshua S. Lipshutz (ARDC No. 6331205) jlipshutz@gibsondunn.com 1050 Connecticut Avenue, N.W. Washington, D.C. 20036 Tel: 202.955.8500 Fax: 202.530.9614 Attorneys for Defendant Facebook, Inc. 3 CERTIFICATE OF SERVICE FILED DATE: 11/21/2023 9:01 AM 2018CH03868 I, Elizabeth Blackston, an attorney, hereby certify that I caused to be served the above and foregoing JOINT MOTION TO STAY PROCEEDINGS FOR ADDITIONAL 120 DAYS by causing a true and accurate copy of such paper to be filed and transmitted to counsel of record for Cook County and for Defendant Facebook, Inc. via the Court’s CM/ECF electronic filing system, on this 21st day of November, 2023. /s/ Elizabeth Blackston 4