Google Inc. v. American Blind & Wallpaper Factory, Inc.

Filing 122

Declaration of CAROLINE C. PLATER In Support of ABWFI's Reply In Support of Motion to Amend and Extend Case Management Order Dates filed byAmerican Blind & Wallpaper Factory, Inc., American Blind & Wallpaper Factory, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L)(Andelman, Ethan) (Filed on 6/20/2006)

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Google Inc. v. American Blind & Wallpaper Factory, Inc. Doc. 122 Case 5:03-cv-05340-JF Document 122 Filed 06/20/2006 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606 Robert N. Phillips (SBN 120970) Ethan B. Andelman (SBN 209101) HOWREY SIMON ARNOLD & WHITE, LLP 525 Market Street, Suite 3600 San Francisco, CA 94105 Telephone: (415) 848-4900 Facsimile: (415) 848-4999 David A. Rammelt (Admitted Pro Hac Vice) Susan J. Greenspon (Admitted Pro Hac Vice) Dawn M. Beery (Admitted Pro Hac Vice) KELLEY DRYE & WARREN LLP 333 West Wacker Drive, Suite 2600 Chicago, IL 60606 Telephone: (312) 857-7070 Facsimile: (312) 857-7095 Attorneys for Defendant/Counter-Plaintiff AMERICAN BLIND AND WALLPAPER FACTORY, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA GOOGLE INC., a Delaware corporation, Plaintiff, v. AMERICAN BLIND & WALLPAPER FACTORY, INC., a Delaware corporation d/b/a decoratetoday.com, Inc.; and DOES 1100, inclusive, Defendants. AMERICAN BLIND & WALLPAPER FACTORY, INC., a Delaware corporation d/b/a decoratetoday.com, Inc., Counter-Plaintiff, v. GOOGLE, INC., Counter-Defendants Case No. C 03-5340-JF (EAI) DECLARATION OF CAROLINE C. PLATER IN SUPPORT OF AMERICAN BLIND & WALLPAPER FACTORY INC.'S REPLY IN SUPPORT OF MOTION TO AMEND AND EXTEND CASE MANAGEMENT ORDER DATES Date: June 23, 2006 Time: 9:30 a.m. Courtroom: 3 Hon. Jeremy Fogel CH01/PLATC/210352.1 Dockets.Justia.com Case 5:03-cv-05340-JF Document 122 Filed 06/20/2006 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606 I, Caroline C. Plater declare as follows: 1. I am an attorney at Kelley Drye & Warren LLP, counsel of record for Defendant/Counter-Plaintiff American Blind & Wallpaper Factory, Inc. ("American Blind") in the above-captioned action. I am a member in good standing of the State Bar of Illinois. I have personal knowledge of the facts set forth in this declaration and, if called as a witness, could and would testify competently to such facts under oath. 2. Attached hereto as Exhibit A is a true and correct copy of June 6, 2006 correspondence from Caroline C. Plater to Ajay Krishnan and Klaus Hamm. 3. Attached hereto as Exhibit B is a true and correct copy June 14, 2006 correspondence from Caroline C. Plater to Ajay Krishnan. 4. Attached hereto as Exhibit C is a true and correct copy June 12, 2006 correspondence from Caroline C. Plater to Klaus Hamm. 5. Attached hereto as Exhibit D is a true and correct copy June 13, 2006 correspondence from Caroline C. Plater to Klaus Hamm. 6. Attached hereto as Exhibit E is a true and correct copy of American Blind and Wallpaper Factory Inc.'s Responses to Google Inc.'s Second Set of Request For Admissions. 7. Attached hereto as Exhibit F is a true and correct copy of American Blind and Wallpaper Factory Inc.'s Responses to Google Inc.'s Second Set of Request For Production of Documents and Things. 8. Attached hereto as Exhibit G is a true and correct copy of American Blind and Wallpaper Factory Inc.'s Responses to Google Inc.'s Second Set of Interrogatories. 9. Attached hereto as Exhibit H is a true and correct copy of June 20, 2006 correspondence from Caroline C. Plater to Ajay Krishnan. 10. Attached hereto as Exhibit I is a true and correct copy of January 3, 2006 correspondence from Klaus Hamm to David Rammelt. 11. Attached hereto as Exhibit J are true and correct copies of American Blind's 30(b)(6) Notice dated January 31, 2006 and Amended Notice dated February 14, 2006. 12. Attached hereto as Exhibit K is a true and correct copy of American Blind's -2- CH01/PLATC/210352.1 Case 5:03-cv-05340-JF Document 122 Filed 06/20/2006 Page 3 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606 30(b)(6) Notice dated February 14, 2006 for the person most knowledgeable of Google's document production. 13. Attached hereto as Exhibit L is a true and correct copy of American Blind's Deposition Notice of Prashant Fuloria, dated April 14, 2006. I declare under penalty of perjury that the foregoing is true and correct. Executed this 20th day of June 2006, in Chicago, Illinois. __/s/ Caroline C. Plater___________ CAROLINE C. PLATER CH01/PLATC/210352.1 -3-

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