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

Filing 74

Declaration of Gill Sperlein in Support of Plainitff's Motion for Order Allowing Parties to Exceed Otherwise Applicable Page Limitations 73 by IO Group, Inc. (Related document(s) 73 ) (Sperlein, Dennis) (Filed on 7/20/2007) Text modified on 7/23/2007 to conform to document caption post by counsel (bw, COURT STAFF).

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

Doc. 74

Case 5:06-cv-03926-HRL

Document 74

Filed 07/20/2007

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GILL SPERLEIN (172887) THE LAW FIRM OF GILL SPERLEIN 584 Castro Street, Suite 849 San Francisco, California 94114 Telephone: [phone] X32 Facsimile: [phone] [e-mail] Attorney for Plaintiff IO GROUP, INC.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION IO GROUP, INC., a California corporation, Plaintiff, vs. VEOH NETWORKS, Inc., a California Corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) C-06-03926 (HRL) DECLARATION OF GILL SPERLEIN IN SUPPORT OF PLAINTIFF'S MOTION FOR ORDER ALLOWING PARTIES TO EXCEED OTHERWISE APPLICABLE PAGE LIMITATIONS DATE: April 10, 2007 TIME: 10:00 a.m. COURTROOM: 2 Discovery Cut Off: April 30, 2007 Trial Date: October 24, 2007

I, GILL SPERLEIN, declare: 1. I am an attorney at law licensed to practice in the State of California and attorney of

record for Plaintiff Io Group, Inc. 2. I have conferred with Defense Counsel and both parties intend to file summary

judgment motions in this matter. 3. impression.
-1SPERLEIN DECLARATION IN SUPPORT OF MOTION TO EXCEED PAGE LIMITS C-06-3926 (HRL)

This matter raises complex issues of law some of which are issues of first

Dockets.Justia.com

Case 5:06-cv-03926-HRL

Document 74

Filed 07/20/2007

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4. 5.

This matter involves a detailed and complex factual record. Plaintiff took five depositions and has compiled a large record of uncontraverted

material facts, which will require significant additional pages to present to the Court. 6. In order to adequately brief the Court on the legal and factual issues involved in

this matter, Plaintiff requires a significant increase in the page limitations set forth in local rule 7.2(b). 7. I requested that Defendant stipulate to this motion, but Defendant declined to do so.

Pursuant to the laws of the United States, I declare under penalty of perjury the foregoing is true and correct.

Dated: July 20, 2007

/s/ Gill Sperlein ____________________ GILL SPERLEIN, Attorney for Plaintiff

-2SPERLEIN DECLARATION IN SUPPORT OF MOTION TO EXCEED PAGE LIMITS C-06-3926 (HRL)