Jurin v. Google Inc.

Filing 23

RENEWED MOTION to STAY by Google, Inc. Motion Hearing set for 6/24/2010 at 02:00 PM in Courtroom 7 (MCE) before Judge Morrison C. England Jr. (Attachments: # 1 Declaration Margret M. Caruso)(Caruso, Margaret)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Margret M. Caruso (Bar No. 243473) 2 [e-mail] Cheryl A. Galvin (Bar No. 252262) 3 [e-mail] Eman Sojood (Bar No. 261293) 4 [e-mail] 555 Twin Dolphin Drive, Fifth Floor 5 Redwood Shores, CA 94065-2129 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant 7 Google Inc. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 1. DECLARATION OF MARGRET M. CARUSO I, Margret M. Caruso, hereby declare as follows: I am a member of the Bar of the State of California and a partner of the law firm of DANIEL JURIN, an Individual, Plaintiff, vs. GOOGLE, INC., Defendant. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

CASE NO. 2:09-cv-03065-MCE-KJM DECLARATION OF MARGRET M. CARUSO

24 Quinn Emanuel Urquhart & Sullivan ("Quinn Emanuel"), attorneys of record for defendant 25 Google Inc. ("Google") in this matter. I make this declaration of my personal and firsthand 26 knowledge and, if called and sworn as a witness, I could and would testify competently hereto. 27 2. I submit this Declaration in support of Google Inc.'s Renewed Motion to Stay or in 28 the alternative, to Strike Jurin's First Amended Complaint. 1-

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3.

On or about March 26, 2010, I spoke by telephone with counsel for Daniel Jurin,

2 Paul Bartleson. The substance of that conversation included the following. I told him that Google 3 had not yet received the Court-ordered costs and asked when Mr. Jurin intended to pay them. Mr. 4 Bartleson told me that his client did not have the money to pay the costs. I asked if he expected 5 whether Google would ever be paid, and he said that he did not know. I explained to Mr. 6 Bartleson that I was trying to determine whether Court intervention would be necessary, or 7 whether Mr. Jurin intended to pay Google soon. He said that if I felt it was necessary to seek 8 judicial intervention, I should do so. 9 4. In the time since that conversation, Jurin has still not paid Google the Court-

10 ordered costs or expressed any intent to do so. 11 I declare under penalty of perjury under the laws of the United States of America that the

12 foregoing is true and correct. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2By /s/ Margret M. Caruso Margret M. Caruso Executed this 4th day of April, 2010.

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