Lalo v. Apple, Inc et al

Filing 155

Declaration of Bryan Wilson in Support of 154 Stipulation Joint Stipulation To Extend Briefing Schedule on Defendants' Motions To Dismiss and [Proposed] Order filed byApple, Inc, Quattro Wireless, Inc.. (Related document(s) 154 ) (Wilson, Bryan) (Filed on 7/29/2011)

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JAMES F. MCCABE (SBN 104686)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
BRYAN WILSON (SBN 138842)
[e-mail]
TERESA N. BURLISON (SBN 230854)
[e-mail]
MORRISON & FOERSTER LLP
755 Page Mill Road
Palo Alto, California 94304-1018
Telephone: [phone]
Facsimile: 650.494.0792
Attorneys for Defendants
APPLE INC., a California corporation and
QUATTRO WIRELESS, INC.

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MICHAEL L. CHARLSON (Bar No. 122125)
[e-mail]
MAREN J. CLOUSE (Bar No. 228726)
[e-mail]
HOGAN LOVELLS US LLP
525 University Avenue, 4th Floor
Palo Alto, California 94301
Telephone: [phone]
Facsimile: 650.463.4199
CHRISTOPHER WOLF (Admitted Pro Hac Vice)
[e-mail]
HOGAN LOVELLS US LLP
Columbia Square
555 Thirteenth Street, NW
Washington, DC 20004
Telephone: [phone]
Facsimile: 202.637.5910
CLAYTON C. JAMES (Admitted Pro Hac Vice)
[e-mail]
HOGAN LOVELLS US LLP
One Tabor Center, Suite 1500
1200 Seventeenth Street
Denver, Colorado 80202
Telephone: [phone]
Facsimile: 303.899.7333

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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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In Re iPhone Application Litigation

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Ctrm:
Judge:

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10-CV-05878 LHK (PSG)

DECLARATION OF BRYAN
WILSON IN SUPPORT OF JOINT
STIPULATION TO EXTEND
BRIEFING SCHEDULE ON
DEFENDANTS’ MOTIONS TO
DISMISS

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Case No.

4, 5th Floor
Honorable Lucy H. Koh

I, Bryan Wilson, declare as follows:
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I am an attorney licensed to practice law in all courts in the State of California and

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

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am a partner in the law firm of Morrison & Foerster LLP and am one of the attorneys responsible
WILSON DEC ISO STIPULATION TO EXTEND BRIEFING SCHEDULE ON DEFTS’ MTNS. TO DISMISS
10-CV-05878 LHK (PSG)
pa-1477681

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for the representation of Defendants Apple Inc. (“Apple”) and Quattro Wireless, Inc. (“Quattro”)

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in this matter. I make this declaration of my own personal knowledge, unless the context

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indicates otherwise, and, if called as a witness, I could and would testify competently to the facts

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stated below.

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2.

By order dated June 3, 2011 (Dkt. No. 134), the Court ordered Defendants to file

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any anticipated motions to dismiss the Consolidated Complaint by June 20, 2011, Plaintiffs to file

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an opposition by July 18, 2011, Defendants to file a reply by August 1, 2011, and a set a hearing

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date of September 1, 2011 for such motions.

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3.

Given the common allegations against Defendants, Apple, Quattro, and the other

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Defendants are working to coordinate the filing of their reply briefs, for the convenience of the

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Court and all parties.

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4.

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

their motions to dismiss by two (2) days.
5.

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

the hearing of the motion.
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Defendants have previously requested, and were granted, extensions of their

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respective deadlines to respond to the Consolidated Complaint. Defendants also requested a

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short, one-week extension to file coordinated motions to dismiss, which the Court granted without

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changing the September 1, 2011 hearing date. As then, this requested extension will not alter the

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date of any other event or any other deadline already fixed by Court order – including the

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September 1, 2011 hearing date.

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I declare under the penalty of perjury under the laws of the United States of America that
the foregoing is true and correct.
Executed on July 29, 2011 in Palo Alto, California.

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/s/Bryan Wilson
Bryan Wilson

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WILSON DEC ISO STIPULATION TO EXTEND BRIEFING SCHEDULE ON DEFTS’ MTNS. TO DISMISS
10-CV-05878 LHK (PSG)
pa-1477681

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