IO Group, Inc. v. Veoh Networks, Inc.

Filing 10

Declaration of Dean A. Morehous in Support of 9 Stipulation and (PROPOSED) Order o Extend Time To Respond To Motion to Consolidate filed by Veoh Networks, Inc.. (Related document(s) 9 ) (Morehous, Dean) (Filed on 9/13/2006) Text modified on 9/14/2006 to conform to document post by counsel (bw, COURT STAFF).

IO Group, Inc. v. Veoh Networks, Inc.

Doc. 10

Case 5:06-cv-03926-HRL

Document 10

Filed 09/13/2006

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THELEN REID & PRIEST LLP
ATTORNEYS AT LAW

Dean A. Morehous (CA Bar No. 111841) [e-mail] THELEN REID & PRIEST LLP 101 Second Street Suite 1800 San Francisco, CA 94105 Telephone: [phone] Facsimile: [phone] Michael S. Elkin (pro hac vice pending) [e-mail] Paul M. Fakler (pro hac vice pending) [e-mail] THELEN REID & PRIEST LLP 875 Third Avenue New York, New York 10022 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant VEOH NETWORKS, INC.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION IO GROUP, INC., a California Corporation Plaintiff, v. VEOH NETWORKS, Inc., a California Corporation, Defendant. Case No.: C06-3926 (HRL) DECLARATION OF DEAN MOREHOUS IN SUPPORT OF STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR DEFENDANT VEOH NETWORKS, INC. TO RESPOND TO PLAINTIFF'S MOTION TO CONSOLIDATE

I, DEAN MOREHOUS, declare: 1. I am a partner of the law firm of Thelen Reid & Priest LLP, attorneys of record for

Defendant VEOH Networks, Inc. ("Defendant"), in the above-entitled action. I am admitted to practice in the State of California. The following matters are true of my own personal knowledge and if called upon to do so, I could and would competently testify thereto. 2. Plaintiff filed an Administrative Motion to Consolidate on September 11, 2006.
DECLARATION of D. MOREHOUS IN SUPPORT OF STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR DEFENDANT VEOH NETWORKS, INC. TO RESPOND TO PLAINTIFF'S MOTION TO CONSOLIDATE C 06-3926 (HRL)

-1Based on that date, Plaintiff's response to that motion is due Thursday, September 14, 2006.

Dockets.Justia.com

Case 5:06-cv-03926-HRL

Document 10

Filed 09/13/2006

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THELEN REID & PRIEST LLP
ATTORNEYS AT LAW

3.

However, because of the very recent retention of Thelen Reid & Priest LLP by the

defendant and subsequent substitution of counsel, the parties have stipulated that Defendant may file its response by September 25, 2006. The parties have further stipulated that this agreement will have no effect on any other date currently scheduled in this action. 4. One previous extension has been sought, stipulated to and ordered in this matter,

extending defendant's time to answer plaintiff's complaint until Monday, September 25, 2006. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed in San Francisco, California on the 12th of September, 2006.

/s/ Dean A. Morehous Dean A. Morehous (CA Bar No. 111841) THELEN REID & PRIEST LLP 101 Second Street Suite 1800 San Francisco, CA 94105 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant VEOH NETWORKS, INC.

-2DECLARATION of D. MOREHOUS IN SUPPORT OF STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR DEFENDANT VEOH NETWORKS, INC. TO RESPOND TO PLAINTIFF'S MOTION TO CONSOLIDATE C 06-3926 (HRL)