Jurin v. Google Inc.

Filing 42

DECLARATION of Margret M. Caruso in SUPPORT OF 41 MOTION to DISMISS. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Caruso, Margaret)

Jurin v. Google Inc.

Doc. 42

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Margret M. Caruso (Bar No. 243473) 2 [e-mail] Cheryl A. Galvin (Bar No. 252262) 3 [e-mail] 555 Twin Dolphin Drive, Fifth Floor 4 Redwood Shores, CA 94065-2129 Telephone: [phone] Facsimile: [phone] 6 Attorneys for Defendant Google Inc. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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

23 Quinn Emanuel Urquhart & Sullivan LLP ("Quinn Emanuel"), attorneys of record for Defendant 24 Google Inc. ("Google") in this matter. I make this declaration of my personal and firsthand 25 knowledge and, if called and sworn as a witness, I could and would testify competently hereto. 26 2. I submit this Declaration in support of Google Inc.'s Motion to Dismiss Jurin's 27 Second Amended Complaint. 28 1Dockets.Justia.com

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Attached to this declaration as Exhibit A is a "redlined" document prepared using

2 the Workshare software suite that compares the text of Jurin's First and Second Amended 3 Complaints, with newly added text underlined and newly omitted text stricken through. The 4 redline does not encompass exhibits to the complaints. However, Exhibit A and Exhibit B to the 5 Second Amended Complaint were not attached to either earlier complaint. 6 4. Attached to this declaration as Exhibit B is a true and correct copy, in relevant part,

7 of Google's AdWords Trademark Policies in Sponsored Links, available at 8 http://adwords.google.com/support/aw/bin/answer.py?hl=en&answer=144298 (as printed on 9 October 13, 2010). 10 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 13th day of October, 2010.

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