McKinney v. Google, Inc. et al

Filing 91

Declaration of FRANCE JAFFE in Support of 90 Stipulation STIPULATED REQUEST FOR ORDER CHANGING TIME filed byGoogle, Inc.. (Related document(s) 90 ) (Larrabee, Matthew) (Filed on 4/5/2011)

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1 2 3 4 5 6 7 8 9 MATTHEW L. LARRABEE (No. 97147) DECHERT LLP One Maritime Plaza, Suite 2300 San Francisco, California 94111-3513 Telephone: 415.262.4500 Facsimile: 415.262.4555 STEVEN B.WEISBURD (No. 171490) DECHERT LLP 300 West 6th Street, Suite 2010 Austin, TX 78701 Telephone: 512.394.3000 Facsimile: 512.394.3001 Attorneys for Defendant GOOGLE INC. 10 11 12 13 Rosemarie T. Ring (CA SBN 220769) Henry Weissmann (CA SBN 132418) Sarala Nagala (CA SBN 258712) 560 Mission Street, 27th Floor San Francisco, California 94105-2907 Telephone: 415.512.4000 Facsimile: 415.644.6908 14 15 Attorneys for Defendant HTC CORPORATION 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA 18 SAN JOSE DIVISION 19 20 MARY MCKINNEY, Individually and on behalf of All others Similarly Situated, 21 22 23 24 Plaintiff, Case No. 5:10-CV-01177-JW DECLARATION OF FRANCE JAFFE IN SUPPORT OF STIPULATED REQUEST FOR ORDER CHANGING TIME v. GOOGLE INC., a Delaware Corporation; HTC CORP., a Delaware Corporation; and TMOBILE USA, INC., a Delaware Corporation, 25 Defendants. 26 27 28 DECLARATION OF FRANCE JAFFE I/S/O STIPULATED REQUEST FOR ORDER CHANGING TIME CASE NO. 5:10-CV-01177-JW 1 I, FRANCE JAFFE, declare as follows: 2 1. I am an attorney at the law firm of Dechert LLP, counsel to defendant GOOGLE 3 INC. (“Google”). I make this declaration in support of the parties’ stipulated request for an order 4 changing the time in which defendants Google and HTC CORPORATION must file their reply 5 in support of their motion to dismiss plaintiff Mary McKinney’s Second Amended Complaint. 6 The contents of this declaration are within my personal knowledge and, if called as a witness, I 7 could and would testify competently thereto. 8 9 2. Defendants have requested a one week extension from the deadline set by the local rules of this Court in order to afford sufficient time for Defendants to respond to the 10 arguments and authorities advanced in Plaintiff’s opposition, and thereby provide the Court with 11 proper, full and adequate briefing on the potentially dispositive issues in this case. 12 3. The parties have stipulated to the following time modifications in the case: 13 January 31, 2011 (Docket #81 filed by HTC Corp.), December 17, 2010 (Docket #76), May 21, 14 2010 (Docket #20) and March 29, 2010 (Docket #11 filed by HTC Corp.). 15 4. Although the parties are not requesting that the current April 25, 2011 hearing 16 date be continued, should the Court choose to continue the hearing sua sponte, the schedule of 17 the case will be extended until such time as the Court may hear the motion to dismiss. 18 19 20 I declare under penalty of perjury that the foregoing is true. Executed on April 5, 2011, at San Francisco, California. 21 /s/ France Jaffe France Jaffe 22 23 Attorneys for Defendant GOOGLE INC. 24 25 26 27 28 2 DECLARATION OF FRANCE JAFFE I/S/O STIPULATED REQUEST FOR ORDER CHANGING TIME CASE NO. 5:10-CV-01177-JW

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