Kinderstart.Com, LLC v. Google, Inc.

Filing 18

Case 5:06-cv-02057-JF

Document 18

Filed 05/31/2006

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DAVID H. KRAMER, State Bar No. 168452 COLLEEN BAL, State Bar no. 167637 LISA A. DAVIS, State Bar No. 179854 BART E. VOLKMER, State Bar No. 223732 WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: [phone] Facsimile: [phone] [e-mail] JONATHAN M. JACOBSON WILSON SONSINI GOODRICH & ROSATI Professional Corporation 12 East 49th Street, 30th Floor New York, NY 10017-8203 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Defendant Google Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

KINDERSTART.COM, LLC, a California limited liability company, on behalf of itself and all others similarly situated, Plaintiffs, v. GOOGLE INC., a Delaware corporation, Defendant.

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CASE NO.: C 06-2057 JF (RS) DECLARATION OF DAVID H. KRAMER IN SUPPORT OF DEFENDANT GOOGLE INC.'S MISCELLANEOUS ADMINISTRATIVE REQUEST UNDER L.R. 7-11 TO CONTINUE OR VACATE PRELIMINARY INJUNCTION HEARING DATE

DECLARATION OF DAVID H. KRAMER IN SUPPORT OF GOOGLE'S MISCELLANEOUS ADMINISTRATIVE REQUEST TO CONTINUE OR VACATE HEARING DATE Case No. 06-2057 JF (RS)

Case 5:06-cv-02057-JF

Document 18

Filed 05/31/2006

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I, David H. Kramer, declare: 1. I am a partner at Wilson Sonsini Goodrich & Rosati, counsel for Defendant

Google Inc ("Google"). I have personal knowledge of the facts set forth herein, and would and could testify competently thereto if called as a witness. 2. Gregory J. Yu, counsel for plaintiff Kinderstart.com LLC ("Kinderstart"), and I

have previously discussed whether Kinderstart would agree to postpone the hearing date on Kinderstart's motion for preliminary injunction until after the Court decides Google's motion to dismiss and anti-SLAPP motion. Kinderstart has refused that approach and has instead sought to have its preliminary injunction motion heard on or before the same date that Google's motions are heard. I tried calling Mr. Yu again today to try once again to convince him to postpone the hearing date on Kinderstart's motion for preliminary injunction, but I was unable to reach him.

I declare under penalty of perjury that the foregoing is true and correct. Signed this 31st day of May, 2006 in Palo Alto, California.

/s/ David H. Kramer

DECLARATION OF DAVID H. KRAMER IN SUPPORT OF GOOGLE'S MISCELLANEOUS ADMINISTRATIVE REQUEST TO CONTINUE OR VACATE HEARING DATE Case No. 06-2057 JF (RS)

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