Berkeley Law & Technology Group, LLP v. Cool

Filing 13

Berkeley Law & Technology Group, LLP v. Cool

Doc. 1

Johnathan E. Mansfield, OSB #055390 Email [e-mail] Tiffany A. Harris, OSB #023187 Email [e-mail] Schwabe, Williamson & Wyatt, P.C. Pacwest Center 1211 SW 5th Ave., Suite 1900 Portland, OR 97204 Telephone [phone] Fax [phone] Of Attorneys for Defendant, Kenneth J. Cool

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

BERKELEY LAW & TECHNOLOGY GROUP, LLP, an Oregon limited liability partnership, Plaint iff, vs. KENNETH J. COOL, a Colorado resident, Defendant.

No. CV 07-709 BR DECLARATION OF TIFFANY A. HARRIS IN SUPPORT OF DEFENDANT'S SECOND UNOPPOSED MOTION TO EXTEND TIME TO ANSWER FIRST AMENDED COMPLAINT

I, Tiffany A. Harris, do declare and say that under the penalty of perjury and the laws of the State of Oregon that the following is true. 1. I am an attorney at the law firm of Schwabe Williamson & Wyatt and one of the

attorneys representing defendant Kenneth Cool in this matter. 2. I have conferred with plaintiff's counsel Lawrence Reichman, and plaintiff does

not oppose defendant's second request for an extension of time to appear and answer plaintiff's First Amended Complaint. Page 1 - DECLARATION OF TIFFANY A. HARRIS IN SUPPORT
OF SECOND UNOPPOSED MOTION TO EXTEND TIME TO ANSWER FIRST AMENDED COMPLAINT
PDX/117213/154514/TH/1560896.1
SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law Pacwest Center 1211 SW 5th Ave., Suite 1900 Portland, OR 97204 Telephone [phone]

Dockets.Justia.com

3.

The Court has already granted one such unopposed motion (for a 14-day

extension). This request is for an additional seven days. Since the time that defendant filed his first unopposed motion, the parties have been actively engaged in settlement discussions, which are ongoing.

I hereby declare under penalty of perjury that the foregoing is true and correct. Dated this 25th day of June, 2007.

__/s/ Tiffany A. Harris____________ Tiffany A. Harris

Page 2 -

DECLARATION OF TIFFANY A. HARRIS IN SUPPORT OF SECOND UNOPPOSED MOTION TO EXTEND TIME TO ANSWER FIRST AMENDED COMPLAINT

SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law Pacwest Center 1211 SW 5th Ave., Suite 1900 Portland, OR 97204 Telephone [phone]

PDX/117213/154514/TH/1560896.1