`
`IRELL & MANELLA LLP
`
`
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua P. Glucoft (SBN 301249)
`jglucoft@irell.com
`Casey Curran (SBN 305210)
`ccurran@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Rebecca L. Carson (SBN 254105)
`rcarson@irell.com
`Kevin Wang (SBN 318024)
`kwang@irell.com
`840 Newport Center Drive, Suite 400
`Newport Beach, California 92660-6324
`Telephone: (949) 760-0991
`Facsimile: (949) 760-5200
`
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
`FINJAN, INC.,
`
`
`Plaintiff,
`
`v.
`
`
`
`
`JUNIPER NETWORKS, INC.,
`
`
`Defendant.
`
`
`
`
`
`
`
`Case No. 3:17-cv-05659-WHA
`
`DECLARATION OF JOSHUA GLUCOFT
`IN SUPPORT OF DEFENDANT JUNIPER
`NETWORKS, INC.’S ADMINISTRATIVE
`MOTION TO DEFER PATENT LOCAL
`RULE 4
`
`
`Hon. William H, Alsup
`
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10482099
`
`
`- 1 -
`
`DEC. OF JOSHUA GLUCOFT ISO JUNIPER’S
`ADMINISTRATIVE MOTION TO DEFER
`PATENT LOCAL RULE 4
`Case No. 3:17-cv-05659-WHA
`
`
`
`Case 3:17-cv-05659-WHA Document 52-1 Filed 04/11/18 Page 2 of 2
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`DECLARATION OF JOSHUA GLUCOFT
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`I, Joshua Glucoft, declare as follows:
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`1. I am an attorney at the law firm of Irell & Manella LLP, counsel of record for Juniper
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`Networks, Inc. in the above-captioned action. I am a member in good standing of the State
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`Bar of California and have been admitted to practice before this Court. I have personal
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`knowledge of the facts set forth in this Declaration and, if called as a witness, could and
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`would testify competently to such facts under oath.
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`2. Juniper Networks, Inc. (“Juniper”) is requesting that this Court defer Patent Local Rule 4
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`to commence on January 11, 2019. The reasons for such deferral as well as the prejudice
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`that would occur if Patent Local Rule 4 is not deferred are set forth in the accompanying
`
`administrative motion.
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`3. The parties communicated via email and also met and conferred telephonically at least on
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`April 3, 2018 regarding Juniper’s request to defer Patent Local Rule 4.
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`4. On March 22, 2018, Finjan identified claim 10 of U.S. patent no. 8,677,494 for early
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`summary judgment, and Juniper identified claim 1 of U.S. Patent no. 6,804,780 for early
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`summary judgment.
`
`5. The parties previously stipulated to Juniper’s request for an extension of time for Juniper
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`to respond to the Complaint. The parties also previously stipulated to Finjan’s request to
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`continue the Case Management Conference. See Dkt. No. 21 at p. 1.
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`Executed on April 11, 2018 at Los Angeles, California.
`
`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Dated: April 11, 2018
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`Respectfully submitted,
`
`IRELL & MANELLA LLP
`
`By:
`
`
` /s/ Joshua Glucoft
`Joshua Glucoft
`
`
`
`
`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10482099
`
`
`- 2 -
`
`DEC. OF JOSHUA GLUCOFT ISO JUNIPER’S
`ADMINISTRATIVE MOTION TO DEFER
`PATENT LOCAL RULE 4
`Case No. 3:17-cv-05659-WHA
`
`
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