Exhibit A

Case: 1:20-cv-04699 Document #: 48-1 Filed: 09/08/20 Page 1 of 5 PageID #:800
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

IN RE: TIKTOK, INC., )

CONSUMER PRIVACY ) MDL No. 2948

LITIGATION, )

) Master Docket No. 20 C 4699

)

) Judge John Z. Lee

)

) Magistrate Judge Sunil R. Harjani

This Document Relates to All Cases )

DECLARATION OF SHANNON M. MCNULTY 

I, Shannon M. McNulty, pursuant to 28 U.S.C. § 1746, hereby declare on oath as follows: 

1. I am a partner at, Clifford Law Offices, P.C. I am over the age of eighteen, licensed to 

practice law in the State of Illinois, and I am fully competent to make this declaration. I make this 

declaration based upon personal knowledge unless otherwise indicated. If called upon to testify as to 

the matters stated herein, I could and would competently do so.

2. I have never been sanctioned; nor have I been the subject of any complaint of alleged 

wrongdoing, or any Order inferring any questionable conduct.

3. I have practiced law for more than sixteen years at Clifford Law Offices, P.C. I actively 

engage in all practice areas in my firm, though I have oversight of the firm’s consumer and mass/class 

action practice. 

4. Irrespective of case type, my personal practice standard, and that of Clifford Law 

Offices, is to prepare every case for trial. I have used that standard for my entire career, and approach 

all cases in which I am involved with a goal of trial. I am a trial lawyer. As a condition of firm 

membership, Clifford Law Offices expects partners at the firm to prepare all cases so as to be trialCase: 1:20-cv-04699 Document #: 48-1 Filed: 09/08/20 Page 2 of 5 PageID #:801
2

ready. 

5. An additional practice standard to which I personally adhere, and which is a condition 

of employment at Clifford Law Offices, is the promotion of civility, professionalism and ethics in the 

profession. Those values are compatible with rigorous advocacy. I favor working with lawyers who 

promote the same. 

6. I have been appointed as lead counsel or liaison counsel in several mass tort and class 

action cases. I am profoundly aware of a plaintiff’s burden of proof in a variety of cases, including for 

cases with the scope and complexity of the case sub judice. I acutely appreciate the need for cooperation 

and coordination in the work up of consolidated litigation. 

7. Moreover, in several cases for which Robert A. Clifford has been appointed lead 

counsel or liaison counsel, I have personally participated in the daily advancement, coordination, and 

completion of such cases. 

8. Cases for which I have served in a leadership appointments, either by direct order, or 

in conjunction with Bob Clifford, with me having daily responsibility for the development of the case, 

are as follows: 

Eubank, et al., v. Pella Window Corporation, Case No. 06 C 4481 (Robert A. Clifford 

appointed as Lead Counsel); 

In Re: Dealer Management Systems Antitrust Litigation, MDL No. 2817, Case No. 18 C 864

(Robert A. Clifford appointed as Liaison Counsel); 

In Re: Herbal Supplements Marketing And Sales Practices Litigation, MDL Nos. 2619, 2620, 

2621, 2622, Case No. 15-cv-5070 (Clifford Law Offices appointed as co-chair of lead 

counsel committee with Hagens Berman);

In Re: National Collegiate Athletic Association Student-Athlete Concussion Injury Litigation, 

MDL No. 2492, Master Docket No. 16 C 8727 (Shannon M. McNulty appointed as 

liaison counsel);

In re DePuy Hip Litigation, Circuit Court of Cook County, Case No. 10 L 10506

(Shannon M. McNulty appointed as co-lead counsel with Peter J. Flowers);

In re Talcum Powder Litigation, Circuit Court of Cook County, Case No. 17 L 2169

Case: 1:20-cv-04699 Document #: 48-1 Filed: 09/08/20 Page 3 of 5 PageID #:802
3

(Shannon M. McNulty appointed as co-lead counsel with Peter J. Flowers); 

In re Advocate Data Breach Litigation, Circuit Court of Cook County, Case No. 13 CH 

20390 (Robert A. Clifford appointed as co-lead with Jay Edelson); 

In re Sterigenics EtO Litigation, Circuit Court of Cook County, Case No. 18 L 10475 

(Shannon M. McNulty appointed as a co-lead counsel)

9. In each of the aforesaid cases, the undersigned had daily responsibilities concerning 

the advancement of the case, and in all instances those efforts were coordinated with other counsel.

10. In several instances of the cases cited, namely, in Pella, Herbal Supplements, DePuy Hips, 

Talcum Powder and Advocate, the undersigned had significant oversight of the cases, including all 

pleadings, discovery, trial strategy, settlement discussions, and coordination of firms and assignments. 

Even so, the undersigned collaborated with other Plaintiff’s counsel for the benefit of the case. 

11. The undersigned frequently appears on matters in the Northern District of Illinois, 

with more than a dozen cases currently pending in the District. 

12. The undersigned has been recognized by her peers for contributions to the profession. 

Most recently, Ms. McNulty was nominated and, on September 7, 2020, received, the 2020 Crain’s 

Chicago Business Notable Women in Law award. Moreover, Ms. McNulty has been recognized as a 

Best Lawyers® in America, 2015 – 2021; a Chicago Daily Law Bulletin & Chicago Lawyer Women in 

Law Honoree, 2020; a Leading Lawyer, Law Bulletin Media, 2018 – Present; an Illinois Super Lawyers 

list, 2016 – Present; a Most Influential Women Lawyers in Chicago, Crain’s Custom Media, 2017; an 

Illinois Super Lawyers Rising Star, 2009 – 2014; and, Chicago Law Bulletin’s Forty Under 40, 2007. 

13. Unquestionably, Shannon M. McNulty satisfies the criteria for serving as liaison 

counsel and is capable of serving as liaison counsel in the case at bar. 

14. Committed to the position, Ms. McNulty understands the factual and legal 

complexities of the issues; the global aspects of the case that potentially affect discovery; the timeCase: 1:20-cv-04699 Document #: 48-1 Filed: 09/08/20 Page 4 of 5 PageID #:803
4

sensitivities, and the demands that the features of the case impose. Located in Chicago, a convenience 

to the Court and all counsel, Ms. McNulty has the rigor, commitment and resources for which Clifford 

Law Offices is known. Clifford Law Offices has more than adequate resources to support the 

litigation.

I declare under penalty of perjury that the foregoing is true and correct. 

Date: September 8, 2020 /s/Shannon M. McNulty

 Shannon M. McNulty

Kristofer S. Riddle

CLIFFORD LAW OFFICES, P.C.

120 N. LaSalle Street, 31st Floor

Chicago, Illinois 60602

312.899.9090

SMM@cliffordlaw.com

KSR@cliffordlaw.com

Attorneys for Plaintiffs Cherise Slate, on behalf of 

minor P.S.; Brenda Washington, on behalf of minor 

M.W.; Gilda Avila, on behalf of minor A.R.; 

Meghan Smith; Mikhaila Woodall, on behalf of 

minors C.W and I.W., Misty Hong; Laurel 

Slothwer, on behalf of minor A.S.; Lynn Pavalon, on 

behalf of minor R.P.

Case: 1:20-cv-04699 Document #: 48-1 Filed: 09/08/20 Page 5 of 5 PageID #:804