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)

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1 Scott A. Kamber (admitted pro hac vice) 2 David A. Stampley (admitted pro hac vice) 3 KamberLaw, LLC 100 Wall Street, 23rd Floor 4 New York, New York 10005 Telephone: (212) 920-3072 5 Facsimile: (212) 920-3081 6 Avi Kreitenberg (SBN 266571) 7 KamberLaw, LLP 1180 South Beverly Drive, Suite 601 8 Los Angeles, California 90035 Telephone: (310) 400-1050 9 Facsimile: (310) 277-0635 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, 16 17 Case No.: 5:10-cv-05035-EJD v. GOOGLE INC., a Delaware Corporation, Defendant. 19 20 I, David A. Stampley, declare as follows: 21 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. 28 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. 18 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: (212) 920-3072 Facsimile: (212) 920-3081 21 22 23 24 25 Attorneys for Plaintiff 26 27 28 Stampley Decl. in Support of Stip. Req. to Change Time 2 Case No.: 5:10-cv-05035-EJD

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