Digital Envoy Inc., v. Google Inc.,
Filing
66
DECLARATION of Timothy H. Kratz in Opposition to
64 Brief
In Opposition to Goggle, Inc.'s Motion to Shorten Time filed byDigital Envoy,Inc.,, Digital Envoy,Inc.,. (Related document(s)
64) (Blackman, Brian) (Filed on 1/20/2005)
Digital Envoy Inc., v. Google Inc.,
Doc. 66
Case 5:04-cv-01497-RS
Document 66
Filed 01/20/2005
Page 1 of 2
1 P. CRAIG CARDON, Cal. Bar No. 168646
BRIAN R. BLACKMAN, Cal. Bar No. 196996 2 KENDALL M. BURTON, Cal. Bar No. 228720 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 3 Four Embarcadero Center, 17th Floor San Francisco, California 94111-4106 4 Telephone: 415-434-9100 Facsimile: 415-434-3947
5 6 TIMOTHY H. KRATZ (Admitted Pro Hac Vice)
LUKE ANDERSON (Admitted Pro Hac Vice) 7 MCGUIRE WOODS, L.L.P 1170 Peachtree Street, N.E., Suite 2100 8 Atlanta, Georgia 30309 Telephone: 404.443.5500 9 Facsimile: 404.443.5751
10 Attorneys for DIGITAL ENVOY, INC. 11 12 13 14 DIGITAL ENVOY, INC., 15 16
v. Plaintiff/Counterdefendant, DECLARATION OF TIMOTHY H. KRATZ IN OPPOSITION TO GOOGLE, INC.'S MOTION TO SHORTEN TIME Defendant/Counterclaimant. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION Case No. C 04 01497 RS
17 GOOGLE, INC., 18 19 20 21
I, Timothy H. Kratz, declare as follows: 1. I am an attorney of law duly licensed to practice in the State of Georgia and
22 admitted to practice before this court pro hac vice. I am a partner at the firm McGuireWoods LLP 23 and attorney for the Plaintiff/Counterdefendant Digital Envoy, Inc. ("Digital Envoy"). I have 24 personal knowledge of all facts set forth herein. 25
2. The opposed the briefing schedule set forth in Google, Inc.'s ("Google") Motion
26 for Protective Order would prejudice Digital Envoy because it does not afford counsel for Digital 27 Envoy sufficient time to draft an adequate response brief. 28
W02-SF:5BB\61441617.1
-1Dockets.Justia.com
Case 5:04-cv-01497-RS
Document 66
Filed 01/20/2005
Page 2 of 2
1
3.
If Digital Envoy is allowed to file its response brief two days later, on January 24,
2 2005, counsel for Digital Envoy will have sufficient time to draft an adequate response brief. 3
4. As counsel for Digital Envoy, I stipulated to the hearing date for Google's Motion
4 for Protective Order to be on January 26, 2005. This stipulation was made in a good faith effort to 5 allow Google the opportunity to have its motion heard before responses to Digital Envoy's non6 party subpoenas become due. 7
5. My refusal to stipulate to Google's briefing schedule was done solely to protect the
8 rights of my client and to ensure Digital Envoy's legal team was given sufficient time to draft a 9 response brief. 10
I declare under penalty of perjury under the laws of the United States of America that the
11 foregoing is true and correct. Executed on January 20, 2005, at Atlanta, Georgia. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
W02-SF:5BB\61441617.1
/s/ Timothy H. Kratz_____ Timothy H. Kratz
-2-
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?