Bradley v. Google, Inc. et al

Filing 34

Statement of Non-Opposition [32] Defendant's Statement of Non-Opposition to Plaintiff's Motion for Leave of Court to Dismiss Action filed byGoogle, Inc.. (Shen, Andrew) (Filed on 2/14/2007) Modified on 2/15/2007 (sis, COURT STAFF).

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Bradley v. Google, Inc. et al Doc. 34 Case 3:06-cv-05289-WHA Document 34 Filed 02/14/2007 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 ASHOK RAMANI - #200020 ANDREW N. SHEN - #232499 710 Sansome Street San Francisco, CA 94111-1704 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 Attorneys for Defendants GOOGLE, INC., GOOGLE ADSENSE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION THERESA B. BRADLEY, Psy.D./JD, Plaintiff, v. GOOGLE, INC., GOOGLE ADSENSE, Defendants. Case No. C-06-05289-WHA DEFENDANT'S STATEMENT OF NONOPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE OF COURT TO DISMISS ACTION Date: Time: Dept: TBD TBD Courtroom 9 August 28, 2006 Date Comp. Filed: Trial Date: TBD 1 389739.01 DEFENDANT'S STATEMENT OF NON-OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE OF COURT TO DISMISS ACTION CASE NO. C-06-05289-WHA Dockets.Justia.com Case 3:06-cv-05289-WHA Document 34 Filed 02/14/2007 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 Pursuant to Civil L.R. 7-3(b), defendant Google, Inc. ("Google") hereby informs the Court that it does not oppose plaintiff Theresa B. Bradley's ("Bradley's") Motion for Leave of Court to Dismiss Action except for plaintiff's request "for admonishment by the Court of the Defendants for intentional intrusion and destruction of electronic evidence under the control of Google, Inc. in the Plaintiff's gMail account AFTER the filing of the Complaint." Motion at 4. The "admonishment" sought by plaintiff's motion is inappropriate and unwarranted, especially in light of plaintiff's failure to establish the merits of any of her causes of action, including her unfounded claims that Google has either unjustifiably deleted her e-mail messages or unlawfully intruded into her Gmail account. Dated: February 14, 2007 KEKER & VAN NEST, LLP By: /s/ Andrew N. Shen Attorneys for Defendants GOOGLE, INC., GOOGLE ADSENSE 2 389739.01 DEFENDANT'S STATEMENT OF NON-OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE OF COURT TO DISMISS ACTION CASE NO. C-06-05289-WHA

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