Pimental v. Google, Inc. et al

Filing 48

MOTION for Leave to File Excess Pages filed by Jessica Franklin, Nicole Pimental. (Attachments: # 1 Declaration, # 2 Proposed Order)(Balabanian, Rafey) (Filed on 12/7/2011)

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SEAN P. REIS (SBN 184044)
([e-mail])
EDELSON MCGUIRE LLP
30021 Tomas Street, Suite 300
Rancho Santa Margarita, California 92688
Telephone: [phone]
Facsimile: [phone]
RAFEY S. BALABANIAN (Admitted Pro Hac Vice)
([e-mail])
EDELSON MCGUIRE LLC
350 North LaSalle Street, Suite 1300
Chicago, IL 60654
Telephone: [phone]
Facsimile: [phone]
JORDAN L. LURIE (130013)
([e-mail])
JOEL E. ELKINS (256020)
([e-mail])
WEISS & LURIE
10940 Wilshire Blvd, 23rd Floor
Los Angeles, CA 90024
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs and the Putative Class

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
NICOLE PIMENTAL and JESSICA
FRANKLIN, individually and on behalf of all
others similarly situated,
Plaintiff,

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v.

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

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Defendants.

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DECLARATION OF RAFEY S. BALABANIAN

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Case No. 11-cv-02585-SBA
DECLARATION OF RAFEY S.
BALABANIAN IN SUPPORT OF
PLAINTIFFS’ ADMINISTRATIVE
MOTION FOR LEAVE TO FILE AN
OVERSIZED BRIEF

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Pursuant to 28 U.S.C. § 1746, I hereby declare and state as follows:
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I am over the age of eighteen and am fully competent to make this declaration.

I make this declaration based upon personal knowledge unless otherwise indicated.
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I am a partner at the law firm of Edelson McGuire LLC, which has been

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retained to represent the named Plaintiffs in this matter, Nicole Pimental and Jessica

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Franklin.

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3.

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Defendants’ Motion to Dismiss raised complex and novel constitutional

issues, which necessitate comprehensive and well-developed arguments to properly oppose.
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To fully address the issues raised in Defendants’ Motion, provide the Court

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with a complete argument, and ensure that Plaintiffs’ interests are fully protected, Plaintiffs

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prepared and filed an opposition totaling just over 22 pages, which is approximately seven

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and a half pages over this Court’s limitation.

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5.

While Plaintiffs made their best efforts to present their arguments in

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opposition to Defendants’ Motion as succinctly as possible, the additional seven pages was

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needed to effectively lay out Plaintiffs’ position.

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I declare under penalty of perjury that the foregoing is true and correct.

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Executed on December 7, 2011 at
Chicago, Illinois.

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DECLARATION OF RAFEY S. BALABANIAN

/s/ Rafey S. Balabanian