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`PERKINS COIE LLP
`Sarah Fowler (Bar No. 264838)
`3150 Porter Drive
`Palo Alto, CA 94304-1212
`Phone: 650.838.4300
`SFowler@perkinscoie.com
`
`PERKINS COIE LLP
`Gene W. Lee (admitted pro hac vice)
`Thomas Matthew (admitted pro hac vice)
`1155 Avenue of the Americas, 22nd floor
`New York, NY 10112-0015
`212.262.6900
`GLee@perkinscoie.com
`TMatthew@perkinscoie.com
`
`Attorneys for Plaintiff Twitter, Inc.
`
`
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`TWITTER, INC.,
`
`Plaintiff,
`
`v.
`VOIP-PAL.COM, INC.
`Defendant.
`
`
`
`Case No. 21-cv-09773-JD
`DECLARATION OF GENE W. LEE IN
`SUPPORT OF TWITTER, INC.’S JOINT
`STIPULATION AND [PROPOSED]
`ORDER TO EXTEND BRIEFING
`DEADLINES AND HEARING DATE FOR
`VOIP-PAL’S MOTION TO DISMISS
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`DECLARATION OF GENE W. LEE IN SUPPORT
`OF STIPULATION TO EXTEND TIME
`
`Case No. 21-CV-09773-JD
`
`
`
`Case 3:21-cv-09773-JD Document 26-1 Filed 02/22/22 Page 2 of 2
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`I, Gene W. Lee, declare as follows:
`1.
`I am a licensed attorney with the law firm Perkins Coie LLP. I am lead counsel of
`record for plaintiff Twitter, Inc., and I am admitted pro hac vice in this action. I have personal
`knowledge of the matters stated in this declaration and would testify truthfully to them if called
`upon to do so.
`2.
`I make this declaration in support of the Parties’ Joint Stipulation and [Proposed]
`Order To Request Extension Of Briefing Deadlines And Hearing Date For VoIP-Pal’s Motion To
`Dismiss, pursuant to Civil Local Rules 6-1(b) and 6-2(a).
`3.
`Twitter requests that the Court extend the deadline for Twitter’s Opposition to VoIP-
`Pal’s Motion To Dismiss (ECF 25) by 14 days. VoIP-Pal agrees to this request provided that the
`Court also extends the deadline for VoIP-Pal’s Reply by 7 days. These extensions would give the
`Parties sufficient time to fully consider and develop the issues and arguments for those briefs.
`4.
`In addition, counsel for Twitter has a long-standing scheduling conflict with the
`hearing date of March 24, 2022, the date that VoIP-Pal noticed for its Motion To Dismiss. Counsel
`for Twitter has a family vacation and a professional conference planned during the week that
`includes March 24, both of which involve travel.
`5.
`The Parties previously stipulated to a 30-day extension of time for VoIP-Pal to
`respond to the Complaint. ECF 10. The Parties have not requested, and the Court has not ordered,
`any other time modifications in this case.
`6.
`No other dates scheduled for this case will be affected by the proposed
`modifications.
`I declare under penalty of perjury that the foregoing is true and correct.
`
`
`Dated: February 22, 2022
`
`
`
`
`By: /s/ Gene Lee
`Gene W. Lee
`
`
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`DECLARATION OF GENE W. LEE IN SUPPORT
`OF STIPULATION TO EXTEND TIME
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`Case No. 21-CV-09773-JD
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