Incorp Services, Inc., v. Legalzoom.com, Inc.,

Filing 20

DECLARATION of Jeffrey M. Rosenfeld re 12 MOTION to Transfer Venue Pursuant to 28 U.S.C 1404(a); Memorandum Of POints and Authorities In Support Thereof; Affidavit of Kathryn Pellman With Exhibit A ; filed by Plaintiff Incorp Services, Inc.,. (DECLARATION OF JEFFREY M. ROSEFELD IN OPPOSITION TO MOTION TO TRANSFER VENUE) (Attachments: # 1 Exhibit (Exhibits A-B))(Kronenberger, Karl)

Incorp Services, Inc., v. Legalzoom.com, Inc.,

Doc. 20

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KRONENBERGER BURGOYNE, LLP Karl S. Kronenberger (admitted pro hac vice) 150 Post Street, Suite 520 San Francisco, CA 94108 Telephone: [phone] Facsimile: [phone] [e-mail] Law Offices of Rasmussen & Kang Dowon S. Kang (Bar No. 7042) (Local Counsel) 330 S. Third Street, Suite 1010 Las Vegas, Nevada 89101 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Plaintiff INCORP SERVICES, INC.

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA INCORP SERVICES, INC., a Nevada corporation, Plaintiff, vs. LEGALZOOM.COM, INC., a Delaware corporation, Defendant. Case No. 2:09-cv-00273-RLH-LRL DECLARATION OF JEFFREY M. ROSENFELD IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANT LEGALZOOM.COM, INC.'S MOTION TO TRANSFER VENUE

Case No. 2:09-cv-00273-RLH-LRL

DECL. OF J. ROSENFELD ISO OPP. TO MOTION TO TRANSFER VENUE
Dockets.Justia.com

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I, Jeffrey M. Rosenfeld, declare as follows: 1. I am an associate at the law firm of Kronenberger Burgoyne, LLP, counsel

of record for plaintiff Incorp Services, Inc. ("Incorp"). Unless otherwise stated, I have personal knowledge of the matters stated herein. 2. I reviewed the Federal Judicial Caseload Statistics for the Central District

of California and the District of Nevada. The statistics revealed that during the 12-month period ending March 31, 2008, the District of Nevada had 1,721 total cases and the Central District of California had 8,548 total cases. A true and correct copy of the U.S. District Courts--Median Time Intervals From Filing to Disposition of Civil Cases table, located at the U.S. Courts' website at

http://www.uscourts.gov/caseload2008/tables/C05Mar08.pdf, was printed on April 6, 2009 and is attached hereto as Exhibit A. 3. On April 6, 2009 I searched the Nevada Secretary of State's website,

located at http://sos.state.nv.us/business/, for all companies that use LegalZoom.com as their registered agent in the State of Nevada. The search revealed that 1,185

companies use LegalZoom as their Nevada agent. Attached hereto as Exhibit B is a true and correct printout of these search results, which I printed out from the Nevada Secretary of State's website on April 6, 2009. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct and that this Declaration was executed this 6th day of April, 2009, in San Francisco, California.

/s/ Jeffrey M. Rosenfeld Jeffrey M. Rosenfeld

Case No. 2:09-cv-00273-RLH-LRL

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DECL. OF J. ROSENFELD ISO OPP. TO MOTION TO TRANSFER VENUE