Weber v. Google, Inc.

Filing 39

STIPULATION requesting enlargement of briefing schedule by Jason Weber. (Attachments: # 1 Declaration D.Stampley i/s/o Request, # 2 Proposed Order)(Stampley, David) (Filed on 8/26/2011)

1 Scott A. Kamber (admitted pro hac vice)
[e-mail]
2 David A. Stampley (admitted pro hac vice)
[e-mail]
3 KamberLaw, LLC
100 Wall Street, 23rd Floor
4 New York, New York 10005
Telephone: [phone]
5
Facsimile: [phone]
6 Avi Kreitenberg (SBN 266571)
[e-mail]
7 KamberLaw, LLP
1180 South Beverly Drive, Suite 601
8 Los Angeles, California 90035
Telephone: [phone]
9 Facsimile: [phone]
10 Attorneys for Plaintiff
11

UNITED STATES DISTRICT COURT

12

NORTHERN DISTRICT OF CALIFORNIA

13

SAN JOSE DIVISION

14 JASON WEBER, individually and on behalf
15 of a class of similarly situated individuals,

18

DECLARATION OF DAVID A.
STAMPLEY IN SUPPORT OF
STIPULATED REQUEST FOR ORDER
CHANGING TIME

Plaintiff,

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Case No.: 5:10-cv-05035-EJD

v.
GOOGLE INC., a Delaware Corporation,
Defendant.

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I, David A. Stampley, declare as follows:

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1.

I am an attorney-at-law duly licensed to practice before all of the courts of the

22 States of New York and, pro hac vice, before this Court. I am a partner of KamberLaw, LLC
23 (“KamberLaw”). I am one of the attorneys responsible for the handling of this litigation on
24 behalf of KamberLaw, LLC. I make this declaration based upon my own personal knowledge.
25

2.

I have actively participated in this litigation since its inception and am fully

26 familiar with those proceedings as well as the proceedings currently pending to resolve this
27 matter.
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3.

I have conferred with Defendant’s counsel regarding the requests in the

Stampley Decl. in Support
of Stip. Req. to Change Time

1

Case No.: 5:10-cv-05035-EJD

1 stipulation to which this declaration is attached and attest that Defendant’s counsel has
2 represented to me that Defendant joins in the stipulation.
3

4.

Plaintiff makes this request due to unanticipated scheduling issues and to take

4 into account potential conflicts with religious holidays.
5

5.

Therefore, Plaintiff makes the foregoing request to file his opposition to

6 Defendant’s Motion to Dismiss (Dkt. 33) by October 7, 2011.
7

6.

Plaintiff also requests that the Court set a date of October 28, 2011 for Defendant

8 to reply to Plaintiff’s opposition to its Motion to Dismiss.
9

7.

The parties have previously stipulated to two extensions of time for Defendant to

10 respond to the complaint originally filed on November 5, 2010, one extension of time for
11 Plaintiff to file his Amended Complaint, and a previous extension for Plaintiff to file his
12 opposition to Defendant’s Motion to Dismiss.
13

8.

The requested time modification will affect the hearing date for Defendant’s

14 Motion to Dismiss and the Case Management Conference currently scheduled by the Court for
15 October 14, 2011 for the hearing on the Motion to Dismiss and the Case Management
16 Conference. Plaintiff suggests a date of November 11, or any later date the Court deems
17 appropriate.
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19 Dated: August 26, 2011

KAMBERLAW, LLC

20
By: s/David A. Stampley
David A. Stampley
100 Wall Street, 23rd Floor
New York, New York 10005
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Attorneys for Plaintiff

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Stampley Decl. in Support
of Stip. Req. to Change Time

2

Case No.: 5:10-cv-05035-EJD