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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MATTHEW L. LARRABEE (No. 97147)
[e-mail]
DECHERT LLP
One Maritime Plaza, Suite 2300
San Francisco, California 94111-3513
Telephone: [phone]
Facsimile: 415.262.4555
STEVEN B.WEISBURD (No. 171490)
[e-mail]
DECHERT LLP
300 West 6th Street, Suite 2010
Austin, TX 78701
Telephone: [phone]
Facsimile: 512.394.3001
Attorneys for Defendant
GOOGLE INC.

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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: [phone]
Facsimile: 415.644.6908

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Attorneys for Defendant
HTC CORPORATION

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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MARY MCKINNEY, Individually and on
behalf of All others Similarly Situated,

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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,

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Defendants.
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DECLARATION OF FRANCE JAFFE I/S/O STIPULATED REQUEST FOR ORDER CHANGING TIME
CASE NO. 5:10-CV-01177-JW

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I, FRANCE JAFFE, declare as follows:

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1.

I am an attorney at the law firm of Dechert LLP, counsel to defendant GOOGLE

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INC. (“Google”). I make this declaration in support of the parties’ stipulated request for an order

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changing the time in which defendants Google and HTC CORPORATION must file their reply

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in support of their motion to dismiss plaintiff Mary McKinney’s Second Amended Complaint.

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The contents of this declaration are within my personal knowledge and, if called as a witness, I

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could and would testify competently thereto.

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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

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arguments and authorities advanced in Plaintiff’s opposition, and thereby provide the Court with

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proper, full and adequate briefing on the potentially dispositive issues in this case.

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3.

The parties have stipulated to the following time modifications in the case:

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January 31, 2011 (Docket #81 filed by HTC Corp.), December 17, 2010 (Docket #76), May 21,

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2010 (Docket #20) and March 29, 2010 (Docket #11 filed by HTC Corp.).

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4.

Although the parties are not requesting that the current April 25, 2011 hearing

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date be continued, should the Court choose to continue the hearing sua sponte, the schedule of

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the case will be extended until such time as the Court may hear the motion to dismiss.

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I declare under penalty of perjury that the foregoing is true. Executed on April 5, 2011,
at San Francisco, California.

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/s/ France Jaffe
France Jaffe

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Attorneys for Defendant GOOGLE INC.

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DECLARATION OF FRANCE JAFFE I/S/O STIPULATED REQUEST FOR ORDER CHANGING TIME
CASE NO. 5:10-CV-01177-JW