Lalo v. Apple, Inc et al

Filing 133

Proposed Order STIPULATION TO EXTEND BRIEFING SCHEDULE ON DEFENDANTS MOTIONS TO DISMISS AND [PROPOSED] ORDER by Admob, Inc. (Attachments: # 1 Affidavit Page Decl. In Support of Stipulation)(Page, Michael) (Filed on 6/3/2011)

1
2
3
4
5
6
7

DURIE TANGRI LLP
MICHAEL H. PAGE (SBN 154913)
[e-mail]
JOSEPH C. GRATZ (SBN 240676)
[e-mail]
GENEVIEVE P. ROSLOFF (SBN 258234)
[e-mail]
217 Leidesdorff Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile:
415-236-6300
Attorneys for Defendant
ADMOB, INC.

8
9

UNITED STATES DISTRICT COURT

10

FOR THE NORTHERN DISTRICT OF CALIFORNIA

11

SAN JOSE DIVISION

12
13
14

In re iPhone Application Litigation

Case No.: 5:10-cv-05878-LHK (PSG)
DECLARATION OF MICHAEL H. PAGE IN
SUPPORT OF STIPULATION TO EXTEND
BRIEFING SCHEDULE ON DEFENDANTS’
MOTIONS TO DISMISS

15
16
17
18
19
20
21
22
23
24
25
26
27
28
PAGE DECL. IN SUPP. STIPULATION TO EXTEND TIME TO RESPOND
CASE NO. 5:10-CV-05878-LHK (PSG)

1
2

I, Michael H. Page, declare as follows:
1.

I am an attorney licensed to practice law in all courts in the State of California and am

3

admitted to practice before the United States District Court, Northern District of California. I am a

4

partner in the law firm of Durie Tangri LLP and am one of the attorneys responsible for the

5

representation of Defendant AdMob, Inc. (“AdMob”) in this matter. I make this declaration of my own

6

personal knowledge, unless the context indicates otherwise, and, if called as a witness, I could and would

7

testify competently to the facts stated below.

8
9

2.

By order dated May 31, 2011 (Dkt. No. 132), the Court ordered Defendants to file any

anticipated motions to dismiss the Consolidated Complaint by June 13, 2011, Plaintiffs to file an

10

opposition by July 11, 2011, Defendants to file a reply by July 25, 2011, and a set a hearing date of

11

September 1, 2011 for such motions.

12

3.

Given the common allegations against Defendants, AdMob and the other defendants are

13

working to coordinate the filing of consolidated motions to dismiss rather than separate motions, for the

14

convenience of the Court and all parties.

15
16
17
18
19

4.

Counsel for all Defendants requested that Plaintiffs agree to extend the time to file their

motions to dismiss by one week.
5.

Plaintiffs’ counsel agreed to the extension so long as it would not materially delay the

hearing of the motion.
6.

Defendants have previously requested, and were granted, extensions of their respective

20

deadlines to respond to the Consolidated Complaint, but no party has previously requested an extension

21

of the briefing schedule on Defendants’ anticipated motion to dismiss as ordered by the Court on May

22

31, 2011, and the requested extension will not alter the date of any other event or any other deadline

23

already fixed by Court order.

24
25

Dated: June 3, 2011

By:

26

/s/ Michael H. Page
MICHAEL H. PAGE

27
28
2
PAGE DECL. IN SUPP. STIPULATION TO EXTEND TIME TO RESPOND
CASE NO. 5:10-CV-05878-LHK (PSG)