Berkeley Law & Technology Group, LLP v. Cool

Filing 9

Declaration of Tiffany A. Harris in Support of Defendant's Unopposed Motion to Extend Time to Answer First Amended Complaint. Filed by Kenneth J. Cool. (Related document(s): Motion for Extension of Time to Answer a Complaint/Petition7.) (Harris, Tiffany)

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Berkeley Law & Technology Group, LLP v. Cool D Doc. Johnathan E. Mansfield, OSB #055390 Email jmansfield@schwabe.com Tiffany A. Harris, OSB #023187 Email tharris@schwabe.com Schwabe, Williamson & Wyatt, P.C. Pacwest Center 1211 SW 5th Ave., Suite 1900 Portland, OR 97204 Telephone 503.222.9981 Fax 503.796.2900 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 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 associate 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 he does not oppose defendant's request for an extension of 14 days to appear and Answer plaintiff's First Amended Complaint, no later than June 25, 2007. Page 1 - DECLARATION OF TIFFANY A. HARRIS IN SUPPORT OF DEFENDANT'S UNOPPOSED MOTION TO EXTEND TIME TO ANSWER FIRST AMENDED COMPLAINT PDX/117213/154514/TH/1555220.1 SCHW ABE, WILLIAMSON & WYATT, P.C. Attorneys at Law Pacwest Center 1211 SW 5th Ave., Suite 1900 Portland, OR 97204 Telephone 503.222.9981 ockets.Justia.com 3. The parties are engaged in efforts to settle this matter before the case is placed at issue. The requested extension of time will facilitate these efforts. I hereby declare that the above statement is true to the best of my knowledge and belief and I understand that it is made for use as evidence in court and is subject to penalty for perjury. Dated this 7th day of June, 2007. __/s/ Tiffany A. Harris____________ Tiffany A. Harris Page 2 - DECLARATION OF TIFFANY A. HARRIS IN SUPPORT OF DEFENDANT'S UNOPPOSED MOTION TO EXTEND TIME TO ANSWER FIRST AMENDED COMPLAINT SCHW ABE, WILLIAMSON & WYATT, P.C. Attorneys at Law Pacwest Center 1211 SW 5th Ave., Suite 1900 Portland, OR 97204 Telephone 503.222.9981 PDX/117213/154514/TH/1555220.1

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