Polaris IP, LLC v. Google Inc. et al

Filing 578

MOTION to Continue Trial and for Additional Time for Trial by Google Inc.. (Attachments: # 1 Affidavit Declaration of M. Kammerud, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Text of Proposed Order)(Perlson, David)

Polaris IP, LLC v. Google Inc. et al

Doc. 578 Att. 1

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BRIGHT RESPONSE, LLC F/K/A POLARIS IP, LLC v. GOOGLE INC., et al. DECLARATION OF MARGARET PIRNIE KAMMERUD IN SUPPORT OF GOOGLE'S EMERGENCY MOTION TO CONTINUE TRIAL DATE AND FOR ADDITIONAL TIME FOR TRIAL 1. I am an associate with the law firm of Quinn Emanuel Urquhart & Sullivan, LLP, NO. 2:07CV-371-TJW-CE

and counsel for Google Inc. ("Google"). I have personal, firsthand knowledge of the facts set forth herein, and if called and sworn as a witness, I could and would testify competently thereto. 2. Attached hereto as Exhibit A is a true and correct copy of relevant portions of the

transcript of the July 28, 2010 pre-trial hearing. 3. Attached hereto as Exhibit B is a true and correct copy of the November 21, 2008

document subpoena served on Anthony Angotti. 4. Attached hereto as Exhibit C is a true and correct copy of the January 6, 2009

letter from Jennifer Kash to John Edmonds. 5. Attached hereto as Exhibit D is a true and correct copy of emails between Andrew

Weiss and Mansi Shah. 6. Attached hereto as Exhibit E is a true and correct copy of emails between

Plaintiff's counsel and defense counsel regarding trial witnesses. emails between Plaintiff's counsel and defense counsel

01980.51452/3610085.1

Dockets.Justia.com

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 1st day of August, 2010, at Marshall, Texas.

/s/ Margaret Pirnie Kammerud Margaret Pirnie Kammerud

01980.51452/3610085.1