Pimental v. Google, Inc. et al

Filing 34

MOTION to Stay Discovery, filed by Google, Inc., Slide, Inc.. Responses due by 10/31/2011. (Attachments: # 1 Declaration, # 2 Proposed Order)(Wilson, Bobbie) (Filed on 10/26/2011) Modified on 10/27/2011 (jlm, COURT STAFF).

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PERKINS COIE LLP
BOBBIE J. WILSON (Bar No. 148317)
JOSHUA A. REITEN (Bar No. 238985)
Four Embarcadero Center, Suite 2400
San Francisco, CA 94111-4131
Telephone: [phone]
Facsimile: [phone]
E-mail:
[e-mail]

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DEBRA R. BERNARD (Pro hac vice)
131 S. Dearborn St., Suite 1700
Chicago, Il 60603
Telephone: [phone]
Facsimile: [phone]
E-mail:
[e-mail]
Attorneys for Defendants
GOOGLE INC. and SLIDE, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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NICOLE PIMENTAL and JESSICA
FRANKLIN, individually and on behalf of
all others similarly situated,

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Plaintiffs,

Case No. 11-cv-02585-SBA
DECLARTION OF BOBBIE J. WILSON IN
SUPPORT OF DEFENDANTS’
ADMINISTRATIVE MOTION FOR A
TEMPORARY STAY OF DISCOVERY

v.
GOOGLE INC., a Delaware corporation,
and SLIDE, INC., a Delaware corporation,

Place:
Judge:

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Defendants.
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This Document Relates to All Actions.

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WILSON DECL. ISO ADMIN. MOT. TO STAY DISCOVERY
Case No. 11-cv-02585-SBA

Courtroom 1, 4th Floor
Hon. Saundra Brown Armstrong

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I, Bobbie J. Wilson, declare:

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1.

I am a member of the State Bar of California and a partner at the law firm Perkins

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Coie LLP, which is counsel for Defendants Google Inc. and Slide, Inc. in the above-captioned

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matter. I make this declaration in support of Defendants’ Administrative Motion For A

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Temporary Stay Of Discovery. I have personal knowledge of the facts set forth herein, and if

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called upon to testify, I could and would competently testify thereto.

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2.

On October 20, 2011, I met and conferred telephonically with counsel for

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Plaintiffs regarding a discovery stay. During that conference, I requested Plaintiffs’ agreement

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that no discovery would proceed until the pleadings are settled. Plaintiffs, through counsel,

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declined to agree.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed this 26th day of October, 2011.

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By: /s/ Bobbie J. Wilson
BOBBIE J. WILSON
Attorneys for Defendants
GOOGLE INC. and SLIDE, INC.

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-1WILSON DECL. ISO ADMIN. MOT. TO STAY DISCOVERY
Case No. 11-cv-02585-SBA