Hendricks v. AT&T Mobility LLC
Filing
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Amended MOTION for Hearing (Adminstrative Relief) filed by AT&T Mobility LLC. (Attachments: # 1 Declaration, # 2 Proposed Order)(Falk, Donald) (Filed on 9/14/2011)
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DONALD M. FALK (SBN 150256)
dfalk@mayerbrown.com
MAYER BROWN LLP
Two Palo Alto Square, Suite 300
3000 El Camino Real
Palo Alto, CA 94306-2112
Telephone: (650) 331-2000
Facsimile: (650) 331-2060
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John Nadolenco (CA Bar No. 181128)
jnadolenco@mayerbrown.com
Lisa W. Cornehl (State Bar No. 232733)
lcornehl@mayerbrown.com
MAYER BROWN LLP
350 South Grand Avenue, 25th Floor
Los Angeles, CA 90071-1503
Telephone:
(213) 229-9500
Facsimile:
(213) 625-0248
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Attorneys for Defendant AT&T Mobility LLC
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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PATRICK HENDRICKS, on behalf of himself
and all others similarly situated,
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Plaintiff,
Case No. CV 11-00409-CRB
DECLARATION OF KEVIN RANLETT
IN SUPPORT OF MOTION FOR
ADMINISTRATIVE RELIEF:
v.
AT&T MOBILITY LLC,
Defendant.
REQUEST FOR ADJUSTMENT OF
HEARING DATE
Judge: Hon. Charles R. Breyer
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DECLARATION OF KEVIN RANLETT IN SUPPORT OF MOTION FOR ADMINISTRATIVE RELIEF
CASE NO. CV 11-00409-CRB
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I, Kevin Ranlett, hereby declare as follows:
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1.
The following facts are of my own personal knowledge, and if called as a witness
I could and would testify competently as to their truth.
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2.
I am an attorney employed by Mayer Brown LLP and am counsel to plaintiff
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AT&T Mobility LLC (“ATTM”) in this action (Hendricks), as well as in Schroeder v. AT&T
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Mobility LLC, No. 3:11-cv-04412-CRB (N.D. Cal.), AT&T Mobility LLC v. Bernardi, No. 3:11-
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cv-03392-CRB (N.D. Cal.), and Blau v. AT&T Mobility LLC, No. 3:11-cv-00541-CRB (N.D.
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Cal.).
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3.
On September 13, 2011, I spoke twice by telephone with Scott Bursor, counsel for
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the defendants in Bernardi, the plaintiffs in Schroeder, and the plaintiff in Hendricks, about
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coordinating the hearings on the cross motions to compel arbitration and for a preliminary
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injunction in Bernardi, the plaintiffs’ petition to compel arbitration in Schroeder, and ATTM’s
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motion to compel arbitration in Hendricks. Currently, the motion for a preliminary injunction in
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Bernardi is scheduled to be heard on October 21, 2011, the other motion in Bernardi and the
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petition in Schroeder are scheduled to be heard on October 14, 2011, and the Hendricks motion
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is scheduled to be heard on September 23, 2011.
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4.
Mr. Bursor indicated that he would be arguing all four motions in Bernardi,
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Schroeder, and Hendricks. He did not indicate that he would be unavailable for a hearing on
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October 21, 2011. He stated, however, that he would not agree to have his motions in those
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cases delayed.
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5.
On September 13-14, 2011, I left several voicemail messages for and sent emails
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to Lenza McElrath III, counsel for the plaintiff in Blau v. AT&T Mobility LLC, No. 3:11-cv-
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00541-CRB (N.D. Cal.), about rescheduling the hearing on ATTM’s motions to compel
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arbitration and to dismiss in that case. In his one responsive email to me, he expressed concern
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about moving the hearing and asked for additional information. But he did not respond to my
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follow-up email and voicemail providing that detail and asking whether he is available on
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October 21, 2011.
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DECLARATION OF KEVIN RANLETT IN SUPPORT OF MOTION FOR ADMINISTRATIVE RELIEF
CASE NO. CV 11-00409-CRB
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ATTM’s lead counsel for the arbitration issues in these four cases, Andrew
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Pincus of Mayer Brown LLP, has a conflicting obligation on October 14, 2011—speaking at the
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American Bar Association Section of Litigation 15th Annual Institute on Class Actions in New
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York.
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I have also been informed that ATTM’s lead counsel for the motion to dismiss in
Blau, Steven Rice of Crowell & Moring LLP, has a conflicting obligation on October 14, 2011.
I declare under penalty of perjury that the foregoing is true and correct. Executed in
Washington, DC on September 14, 2011.
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/s Kevin Ranlett
Kevin Ranlett
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DECLARATION OF KEVIN RANLETT IN SUPPORT OF MOTION FOR ADMINISTRATIVE RELIEF
CASE NO. CV 11-00409-CRB
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