Interserve, Inc. et al v. Fusion Garage PTE. LTD

Filing 47

First MOTION to Compel Documents filed by Fusion Garage PTE. LTD. (Doolittle, Patrick) (Filed on 4/2/2010)

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1 BILL LOCKYER Attorney General of the State of California 2 ROBERT R. ANDERSON Chief Assistant Attorney General 3 GERALD A. ENGLER Senior Assistant Attorney General 4 PEGGY S. RUFFRA Supervising Deputy Attorney General 5 DORIAN JUNG State Bar No. 200116 6 455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102-7004 7 Telephone: (415) 703-1342 Fax: (415) 703-1234 8 Email: dorian.jung@doj.ca.gov Attorneys for Respondent 9 IN THE UNITED STATES DISTRICT COURT 10 FOR THE NORTHERN DISTRICT OF CALIFORNIA 11 SAN JOSE DIVISION 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1. v. JEANNE S. WOODFORD, Director of the California Department of Corrections, Respondent. MICHAEL JOHN YANCEY, Petitioner, C 05-1028 JF DECLARATION OF COUNSEL IN SUPPORT OF APPLICATION FOR FIRST ENLARGEMENT OF TIME TO FILE RESPONSE I, DORIAN JUNG, declare under penalty of perjury as follows: I am a Deputy Attorney General for the State of California and am admitted to practice law in this State and before this Court. I have been assigned to represent respondent in this matter. 2. On April 1, 2005, this Court filed an order to show cause. The present due date for respondent's answer is May 2, 2005. 3. 4. I request an enlargement of time to and including June 1, 2005. I need additional time to file an answer due to time constraints caused by other pending cases. In the past 60 days, I have completed or filed respondent's briefs in People v. Brabo (A106897), People v. Marin (A107557), People v. Patrick (A107292), People v. Dao (H0279009), Decl. of Counsel in Supp. of Appl. for EOT to File Answer - Yancey v. Woodford - C 05-1028 JF 1 1 and People v. Turner (A105680) as well as respondent's opposition in In re Tomas (H028318), 2 Saravia v. Runnels (C04-5038), and Busch v. Woodford (C04-4157). 3 4 5. 6. I have contacted opposing counsel, who stipulates to this request. For the reasons stated, I respectfully request that the Court grant respondent's application 5 for an enlargement of time, to and including June 1, 2005, in which to file the answer to the petition 6 for writ of habeas corpus and relevant portions of the state record. 7 I declare under penalty of perjury of the laws of the State of California and the United States 8 of America that the foregoing is true and correct. Executed at San Francisco, California on April 9 29, 2005. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Decl. of Counsel in Supp. of Appl. for EOT to File Answer - Yancey v. Woodford - C 05-1028 JF /s/ DORIAN JUNG Deputy Attorney General 2

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