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`Gregory Dovel (SBN 135387)
`Email: greg@dovel.com
`Richard Lyon (SBN 229288)
`Email: rick@dovel.com
`DOVEL & LUNER, LLP
`201 Santa Monica Blvd., Suite 600
`Santa Monica, CA 90401
`Telephone: 1.310.656.7066
`Attorneys for Plaintiff
`NETWORK-1 TECHNOLOGIES, INC.
`
`
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`NETWORK-1 TECHNOLOGIES,
`INC.,
`
`Plaintiff,
`
`v.
`HIKVISION USA, INC.,
`Defendant.
`
`
`
`Case No. 2:22-CV-08050 CJC(JDEx)
`DECLARATION OF RICHARD
`LYON IN SUPPORT OF JOINT
`AND UNOPPOSED MOTION TO
`CONTINUE THE HEARING ON
`DEFENDANT’S PARTIAL
`MOTION TO DISMISS AND
`CORRESPODING REPLY BRIEF,
`AND THE DATE TO ISSUE A
`SCHELING ORDER
`Judge: Hon. Cormac J. Carney
`
`
`
`
`
`I, Richard Lyon, declare as follows:
`1.
` I am a partner at the law firm of Dovel & Luner, counsel for Plaintiff
`
`Network-1 Technologies. I submit this declaration in support of the joint and
`unopposed Motion to Continue the hearing on Defendant’s Partial Motion to
`Dismiss and corresponding Reply Brief, and the date to issue a Scheduling Order,
`filed herewith. I know the facts stated herein to be true based upon my own
`
`Declaration of Richard Lyon in Support of Joint
`and Unopposed Motion to Continue
`
`
`
`Case No. 2:22-CV-08050 CJC (JDEx)
`
`
`
`Case 2:22-cv-08050-CJC-JDE Document 34-1 Filed 06/08/23 Page 2 of 2 Page ID #:406
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`personal knowledge or upon my review of the records and files Dovel & Luner
`maintains in the regular course of its representation of the plaintiff. If called and
`sworn as a witness, I could and would testify competently thereto.
`
`2.
`Good cause exists to continue the hearing and the date to issue a
`scheduling order. The parties reached an agreement to settle the case and are in the
`process of documenting the settlement. Continuing the dates will allow the parties
`and the Court to conserve resources over the next three weeks.
`
`3. On June 8, 2023, Plaintiff’s counsel and counsel for Hikvision USA,
`Inc. consented to this motion.
`
`I declare under penalty of perjury under the laws of the United States of
`America that the foregoing is true and correct.
`
`Executed on June 8, 2023 at Santa Monica, California
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`/s/ Richard Lyon
`Richard Lyon
`
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`
`Declaration of Richard Lyon in Support of Joint
`and Unopposed Motion to Continue
`
`
`1
`
`Case No. 2:22-CV-08050 CJC (JDEx)
`
`
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