Netflix, Inc. v. Blockbuster, Inc.

Filing 34

Declaration of Leo L. Lam in Support of 33 MOTION for Leave to File Plaintiff Netflix's Notice of Motion and Motion Under Civil L.R. 7-11 for Relief from July 28, 2006 Deadline in Case Management Order and for Leave to File Amended Complaint filed byNetflix, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Related document(s)33) (Lam, Leo) (Filed on 8/2/2006)

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Netflix, Inc. v. Blockbuster, Inc. Doc. 34 Case 3:06-cv-02361-WHA Document 34 Filed 08/02/2006 Page 1 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 KEKER & VAN NEST, LLP JEFFREY R. CHANIN - #103649 DARALYN J. DURIE - #169825 LEO L. LAM - #181861 710 Sansome Street San Francisco, CA 94111-1704 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 Attorneys for Plaintiff NETFLIX, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA NETFLIX, INC., a Delaware corporation, Plaintiff, v. BLOCKBUSTER, INC., a Delaware corporation, DOES 1-50, Defendant. Case No. C 06 2361 WHA DECLARATION OF LEO L. LAM IN SUPPORT OF NETFLIX'S MOTION FOR RELIEF UNDER CIVIL L.R. 7-11 Date: N/A per Civil L.R. 7-11 Judge: Hon. William Alsup 378163.01 Lam Decl. in Support of Netflix's Motion for Relief Under Civil L.R. 7-11 Case No. C 06 2361 WHA Dockets.Justia.com Case 3:06-cv-02361-WHA Document 34 Filed 08/02/2006 Page 2 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Leo L. Lam, declare as follows: 1. I am a partner with Keker & Van Nest, LLP, counsel of record for Plaintiff Netflix, Inc. in this action. I submit this declaration in support of Netflix's Motion for relief from the July 28 deadline specified in the Court's Case Management Order and for leave to file Netflix's Amended Complaint. I have personal knowledge of the facts set forth below and could and would testify competently thereto if called upon to do so. 2. Attached hereto as Exhibit A is a true and correct copy of Netflix's First Amended Complaint for Patent Infringement and Demand for Jury Trial, filed Wednesday, July 26, 2006. 3. Attached hereto as Exhibit B is a true and correct copy of a letter dated August 1, 2006 from Dominique Thomas, counsel for Defendant Blockbuster, Inc., to Jeffrey Chanin of my firm. 4. Attached hereto as Exhibit C is a true and correct copy of my response letter dated August 1, 2006 to Ms. Thomas. 5. I also left a voice message earlier today (on August 2, 2006) for William O'Brien, counsel for Blockbuster, requesting Blockbuster's stipulation to our filing this motion for relief. As of yet I have not received a response from Ms. Thomas or Mr. O'Brien or other counsel on behalf of Blockbuster regarding our motion. I declare under penalty of perjury that the foregoing statements are true and correct, and that I executed this declaration on August 2, 2006 at San Francisco, California. /s/ Leo L. Lam LEO L. LAM 378163.01 1 Lam Decl. in Support of Netflix's Motion for Relief Under Civil L.R. 7-11 Case No. C 06 2361 WHA

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