Hendricks v. AT&T Mobility LLC

Filing 38

STIPULATION and Proposed Order For Extension of Time To File Reply by AT&T Mobility LLC. (Attachments: # 1 Declaration)(Cornehl, Lisa) (Filed on 8/23/2011)

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I MAYER BROV/N LLP JOHN NADOLENCO (SBN 181128) 2 jnado LISA W J 4 5 .com (sBN 232733) lcornehl@mayerbrown, com 350 South Grand Avenue 25th Floor Los Angeles, CA 90071-1503 Telephone: (213) 229-9500 Facsimile: (213) 625-0248 6 7 MAYER BROWN LLP DONALD M. FALK (S8N150256) 8 dfalk@mayerbrown,com Two Palo Alto Square, Suite 300 3000 El Camino Real Palo Alto, CA 94306-2112 Telephone: (650) 33 I -2000 Facsimile: (650) 33 1 -2060 9 l0 ll Attorneys for Defendant 12 AT&T Mobility LLC l3 UNITED STATES DISTRICT COURT t4 NORTHERN DISTRICT OF CALIFORNIA l5 SAN FRANCISCO DIVISION T6 t7 PATRICK HENDRICKS, on behalf of himself and all others similarly situated, 18 Plaintiff, T9 VS, 20 2l AT&T MOBILITY,LLC, Defendant. Case No. Cl1-00409 CRB DECLARATION OF KEVIN RANLETT IN SUPPORT OF STIPULATION AND IPROPOSEDI ORDER FOR EXTENSION OF TIME Date: September 23,201I Time: l0:00 a.m. Courtroom 8 22 Honorable Charles R. Breyer 23 24 25 26 27 28 DECLARATION OF KEVIN RANLETT; CASE NO. CVI I-OO4O9 CRB 1 2 J 4 5 6 I, Kevin Ranlett, hereby declare as follows: 1. The following facts are of my own personal knowledge, and if called as a witness I could and would testify competently 2. I as to their truth. am an attorney with the law firm of Mayer Brown LLP, and I am one of the counsel for defendant AT&T Mobility LLC ("ATTM") in this case. 3. ATTM requests an eleven-day extension of time to file its Reply in support of its 7 Motion to Compel Arbitration and to Stay Case. The new deadline would be September 9,2011, 8 which is 14 days before the scheduled hearing on the motion on September 23,2011. The 9 hearing date would not be affected 10 ll 12 13 t4 l5 by granting the extension, which ATTM requests to accommodate the scheduling commitments of its counsel, 4. 5. No modifications of time have been entered in this action' On August 19,2011, I spoke with counsel for plaintiff Patrick Hendricks, who agreed not to oppose a request for an eleven-day extension of ATTM's time to file its Reply. I declare under penalty of perjury that the foregoing is true and correct. Executed on August 23,2011, at Washington, D.C. 16 I7 /s Kevin Ranlett Kevin Ranlett 18 19 20 2l 22 23 24 25 26 27 28 DECLARATION OF KEVIN RANLETT; CASE NO. CVII-OO4O9 CRB CERTIFICATE OF SERVICE I I am employed in Los Angeles County, California. I am over the age of 2 eighteen years J and not aparty to the within-entitled action. My business address is 350 South Grand Avenue, 4 25th Floor, Los Angeles, California 90071-1503. On August 23,2011, the following document 5 was served electronically via the CM/ECF system: DECLARATION OF KEVIN RANLETT IN SUPPORT OF STIPULATION AND [PROPOSEDI ORDER FOR EXTENSION OF TIME 6 7 I further certify that I mailed the foregoing document in a sealed envelope with postage 8 thereon fully prepaid, in the United States mail at Los Angeles, California addressed as set forth 9 l0 1l 12 13 t4 below: Aaron P. Davis Barry L. Davis Daniel R. Lever THORNTON DAVIS & FEIN, P.A. 80 SW Eighth Street Miami, FL 33130 Telephone: (305) 446-2646 l5 I am readily familiar with the frrm's practice of collection and processing correspondence 16 for mailing. Under that practice the envelopes would be deposited with the U,S. Postal Service t7 on that same day with postage thereon fully prepaid in the ordinary course of business. I am l8 aware that on motion of the party served, service is presumed invalid T9 or postage meter date is more than one day after date of deposit for mailing in affidavit, direction the service was made. I declare under penalty of perjury under the laws of the State of California that the above 22 23 date I declare that I am employed in the office of a member of the bar of this court at whose 20 2l if postal cancellation is true and correct. Executed on August 23,2011, at Los Angeles, California. 24 25 26 27 28 PROOF OF SERVICE ; CASE NO. CVl l-00409 CRB 700008386

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