Google Inc. v. Traffic Information LLC

Filing 45

Declaration of Thomas H. Shunk. Filed by Google Inc.. (Related document(s): Motion for Extension of Time 44 .) (Markley, Julia)

Julia E. Markley, OSB No. 000791 [e-mail] PERKINS COIE LLP 1120 N.W. Couch Street, Tenth Floor Portland, OR 97209-4128 Telephone: [phone] Facsimile: 503.727.2222 Thomas H. Shunk (Ohio Bar No. 0025793) [e-mail] (admitted pro hac vice) Christina J. Moser (Ohio Bar No. 0074817) [e-mail] (admitted pro hac vice) BAKER & HOSTETLER LLP 3200 National City Center 1900 East Ninth Street Cleveland, Ohio 44114-3485 Telephone: [phone] Facsimile: 216.696.0740 Attorneys for Plaintiff

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION GOOGLE INC., Plaintiff, v. TRAFFIC INFORMATION LLC, Defendant.

No. CV09-642-HU DECLARATION OF THOMAS H. SHUNK IN SUPPORT OF JOINT MOTION TO EXTEND TIME FOR PARTIES TO EXCHANGE IDENTIFICATION OF CLAIM TERMS

I, Thomas H. Shunk, declare:

1-

DECLARATION OF THOMAS H. SHUNK

41063-0024/LEGAL18397439.1

P e r k i n s Coie LLP 1120 N.W. Couch Street, Tenth Floor Portland, OR 97209-4128 Phone: [phone] Fax: [phone]

1.

I am an attorney with the law firm of Baker & Hostetler LLP, and am one of the

attorneys representing plaintiff Google Inc. ("Google") in this matter. I make this declaration based on personal knowledge. 2. Pursuant to the current Scheduling Order (ECF #41), the parties are scheduled to

exchange proposed claim terms to be construed on May 28, 2010. 3. Counsel for defendant Traffic Information LLC, C. Dale Quisenberry, contacted

me requesting an extension of the deadline to exchange proposed claim terms to be construed due to a personal family matter. Mr. Quisenberry and I agreed to a one-week extension. 4. This requested extension will have no impact on any other existing deadlines,

settings, or schedules in this matter. 5. The parties request that the deadline for the parties to exchange proposed claim

terms to be construed be extended for one week until June 4, 2010, to accommodate Traffic's counsel's request. This request is made in good faith and not for the purposes of delay. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct. DATED May 27, 2010

By: s/Thomas H. Shunk

2-

DECLARATION OF THOMAS H. SHUNK

41063-0024/LEGAL18397439.1

P e r k i n s Coie LLP 1120 N.W. Couch Street, Tenth Floor Portland, OR 97209-4128 Phone: [phone] Fax: [phone]