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IO Group, Inc. v. Veoh Networks, Inc. Doc.

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Case 5:06-cv-03926-HRL Document 74 Filed 07/20/2007 Page 1 of 2

1 GILL SPERLEIN (172887)


THE LAW FIRM OF GILL SPERLEIN
2
584 Castro Street, Suite 849
3 San Francisco, California 94114
Telephone: (415) 487-1211 X32
4 Facsimile: (415) 252-7747
5
legal@titanmedia.com

6 Attorney for Plaintiff


IO GROUP, INC.
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9
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
10 SAN JOSE DIVISION
11 )
IO GROUP, INC., a California corporation, ) C-06-03926 (HRL)
12
)
13 ) DECLARATION OF GILL SPERLEIN IN
Plaintiff, ) SUPPORT OF PLAINTIFF’S MOTION
14
vs. ) FOR ORDER ALLOWING PARTIES TO
) EXCEED OTHERWISE APPLICABLE
15
) PAGE LIMITATIONS
16 VEOH NETWORKS, Inc., a California )
Corporation, ) DATE: April 10, 2007
17 ) TIME: 10:00 a.m.
Defendant. ) COURTROOM: 2
18
)
19 ) Discovery Cut Off: April 30, 2007
) Trial Date: October 24, 2007
20 )
21
I, GILL SPERLEIN, declare:
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1. I am an attorney at law licensed to practice in the State of California and attorney of
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record for Plaintiff Io Group, Inc.

25 2. I have conferred with Defense Counsel and both parties intend to file summary
26 judgment motions in this matter.
27
3. This matter raises complex issues of law some of which are issues of first
28
impression.

-1-
SPERLEIN DECLARATION IN SUPPORT OF
MOTION TO EXCEED PAGE LIMITS
C-06-3926 (HRL)

Dockets.Justia.com
Case 5:06-cv-03926-HRL Document 74 Filed 07/20/2007 Page 2 of 2

1 4. This matter involves a detailed and complex factual record.


2
5. Plaintiff took five depositions and has compiled a large record of uncontraverted
3
material facts, which will require significant additional pages to present to the Court.
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6. In order to adequately brief the Court on the legal and factual issues involved in

6 this matter, Plaintiff requires a significant increase in the page limitations set forth in local rule
7 7.2(b).
8
7. I requested that Defendant stipulate to this motion, but Defendant declined to do so.
9

10

11 Pursuant to the laws of the United States, I declare under penalty of perjury the

12 foregoing is true and correct.


13

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Dated: July 20, 2007 /s/ Gill Sperlein
15
____________________
16
GILL SPERLEIN,
17 Attorney for Plaintiff

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-2-
SPERLEIN DECLARATION IN SUPPORT OF
MOTION TO EXCEED PAGE LIMITS
C-06-3926 (HRL)

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