Public.Resource.org v. Sheet Metal and Air Conditioning Contractors' National Association, Inc.

Filing 36

STIPULATION WITH PROPOSED ORDER re 35 Stipulation and Order, Set Motion and Deadlines/Hearings, 22 MOTION for Default Judgment by the Court as to Defendant Sheet Metal and Air Conditioning Contractors' National Association, Inc. Extending Time for Settlement Purposes filed by Public.Resource.org, Sheet Metal and Air Conditioning Contractors' National Association, Inc.. (Attachments: # 1 Declaration of Kathleen Lu in Support of Joint Stipulation and [Proposed] Order to Extend Time for Settlement Purposes)(Lu, Kathleen) (Filed on 6/24/2013)

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CORYNNE MCSHERRY (221504)
[e-mail]
MATTHEW ZIMMERMAN (212423)
[e-mail]
ELECTRONIC FRONTIER FOUNDATION
815 Eddy Street
San Francisco, CA 94109
Telephone: [phone]
Facsimile: [phone]
DAVID HALPERIN (Admitted Pro Hac Vice)
[e-mail]
3333 14th Street NW, Suite 205
Washington, DC 20010

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MOUNTAIN VIEW

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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ANDREW P. BRIDGES (CSB No. 122761)
[e-mail]
JAMES J. VARELLAS III (CSB No. 253633)
[e-mail]
KATHLEEN LU (CSB No. 267032)
[e-mail]
FENWICK & WEST LLP
555 California Street, 12th Floor
San Francisco, CA 94104
Telephone:
415.875.2300
Facsimile:
415.281.1350

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Attorneys for Plaintiff
PUBLIC.RESOURCE.ORG

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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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PUBLIC.RESOURCE.ORG,
Plaintiff,

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v.

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DECLARATION OF KATHLEEN LU
IN SUPPORT OF STIPULATION AND
[PROPOSED] ORDER TO EXTEND
TIME FOR SETTLEMENT PURPOSES

SHEET METAL AND AIR CONDITIONING
CONTRACTORS’ NATIONAL
ASSOCIATION, INC.,

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Case No.: 3:13-cv-00815 SC

Defendant.

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DECLARATION OF KATHLEEN LU

Case No.: 3:13-cv-00815 SC

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I, Kathleen Lu, declare pursuant to 28 U.S.C. § 1746 as follows:

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I am an attorney licensed to practice in California and before this Court. I am an

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associate with Fenwick & West LLP, and counsel for Plaintiff Public.Resource.Org (“Public

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Resource”) in this matter. I have personal knowledge of the matters set forth below, and if called

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to testify, I could and would competently do so.

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2.

On May 29, 2013, Public Resource filed its motion for default judgment (Dkt.

No. 23), noticing a hearing date of July 19th, 2013.
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The Parties stipulated to, and the Court granted, an extension of time to June 27,

2013, for Public Resource to file its reply and any supporting papers.
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Since then, the Parties have discussed settlement and believe a settlement is

MOUNTAIN VIEW

possible. The Parties also believe that additional time would greatly aid the Parties in negotiating

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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and finalizing any settlement. The Parties believe that an extension of time for Public Resource’s

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reply and any supporting papers to July 11, 2013 and re-calendaring of the hearing date to

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July 26, 2013, or a later date convenient for the Court, will provide the parties time to finalize

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such a settlement.

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5.

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This is the second modification of time request in this case, and will not have any

effect on the schedule for the case except for the change in hearing date.
I declare under penalty of perjury under the laws of United States that the foregoing is true
and correct.
Executed this 24th day of June, 2013 at San Francisco, California.

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/s/ Kathleen Lu
Kathleen Lu

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DECLARATION OF KATHLEEN LU

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Case No.: 3:13-cv-00815 SC