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`Lewis Emery Hudnell III (CA SBN 218736)
`lewis@hudnelllaw.com
`Nicolas S. Gikkas (CA SBN 189452)
`nick@hudnelllaw.com
`HUDNELL LAW GROUP
`800 W. El Camino Real, Suite 180
`Mountain View, CA 94040
`Telephone: (650) 564-3698
`
`
`Attorneys for Plaintiff/Defendant
`VOIP-PAL.COM, INC.
`
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
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`VOIP-PAL.COM, INC.,
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`Plaintiff,
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`v.
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`GOOGLE LLC,
`
`
`
`
`Defendant.
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`VOIP-PAL.COM, INC.,
`
`
`Plaintiff,
`
`v.
`
`
`META PLATFORMS, INC. et al.
`
`
`Defendants.
`
`
`TWITTER, INC.,
`
`
`Plaintiff,
`
`v.
`
`
`VOIP-PAL.COM, INC.,
`
`
`
`
`
`
`Case No. 3:22-cv-03199-JD
`DECLARATION OF LEWIS E.
`HUDNELL, III IN SUPPORT OF JOINT
`STIPULATION FOR EXTENSION OF
`MOTION FOR JUDGMENT ON THE
`PLEADINGS AND MOTION TO DISMISS
`BRIEFING SCHEDULE
`
`(CIVIL L.R. 6-1, 6-2, AND 7-12)
`
`Case No. 3:22-cv-03202-JD
`
`
`
`
`
`Case No. 3:21-cv-9773-JD
`
`DECLARATION OF LEWIS E. HUDNELL, III IN SUPPORT OF JOINT
`STIPULATION FOR EXTENSION OF MOTION FOR JUDGMENT ON
`THE PLEADINGS AND MOTION TO DISMISS BRIEFING
`SCHEDULE
`Case Nos. 3:22-cv-03199-JD, 3:22-cv-03202-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 59-1 Filed 03/06/23 Page 2 of 4
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`Defendant.
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`Case Nos. 3:22-cv-03199-JD, 3:22-cv-03202-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 59-1 Filed 03/06/23 Page 3 of 4
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`I, Lewis E. Hudnell, III, declare:
`1. I am counsel for VoIP-Pal.com, Inc. (“VoIP-Pal”) in the above captioned matter. I am a
`member in good standing of the bars of California and New York and am admitted to this Court. I
`am fully familiar with the facts set forth below and could testify competently thereto if called upon
`to do so.
`2. I make this declaration in support of the parties’ Joint Stipulation for Extension of Motion
`for Judgment on the Pleadings and Motion to Dismiss Briefing Schedule under Civil Local Rules
`6-1(b), 6-2(a), and 7-7.
`3. The parties stipulate that VoIP-Pal shall have up to and including March 20, 2023 to file a
`response to Movants’ Motion for Judgment on the Pleadings and Motion to Dismiss. Movants
`shall have up to and including March 30, 2023 to file their reply to VoIP-Pal’s response. VoIP-Pal
`seeks an extension because of its counsel’s unavailability during the response period. VoIP-Pal
`also requires the additional time in order to provide the Court with full and helpful briefing.
`Finally, VoIP-Pal seeks this extension of time because of conflicting deadlines VoIP-Pal has in
`other cases. Accordingly, VoIP-Pal seeks this short extension of time not for delay but for good
`cause and so that justice may be served.
`4. This extension request will not affect any other scheduled dates or events in these actions
`except for the hearing date for the Motion, which Movants intend to renotice for April 13, 2023.
`5. In Case. No. 3:21-9973-JD, on December 28, 2021, VoIP-Pal filed a Stipulation to Extend
`Time to Answer or Otherwise Respond to Complaint by 30 days. Dkt. No. 10.
`6. In Case No. 3:21-cv-9773-JD, the parties filed a Joint Stipulation and Proposed Order to
`Request Extension of Briefing Deadlines and Hearing Date for VoIP-Pal’s Motion to Dismiss on
`February 22, 2022. Dkt. No. 26. The Court granted the Stipulation on February 24, 2022. Dkt.
`No. 27.
`7. In Case No. 3:21-cv-9773-JD, the parties filed a Stipulation with Proposed Order to
`Request Extension Of Briefing Deadlines For VoIP-Pal’s Motion To Dismiss on March 14, 2022.
`Dkt. No. 31. The Court granted the Stipulation on March 17, 2022. Dkt. No. 32.
`
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`3
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`Case Nos. 3:22-cv-03199-JD, 3:22-cv-03202-JD; 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 59-1 Filed 03/06/23 Page 4 of 4
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`8. In Case No. 3:22-cv-3199-JD, the parties filed a Stipulation with Proposed Order to Extend
`Briefing Schedule on September 15, 2022. Dkt. No. 86. The Court granted the Stipulation on
`September 16, 2022. Dkt. No. 87.
`9. No time modifications have been requested in Case No. 3:22-cv-3202-JD since the case
`was transferred to this District.
`
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`I declare under penalty of perjury under the laws of the United States of America that the
`foregoing is true and correct. Executed on March 6, 2023, in Mountain View, California.
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`By:
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`/s/Lewis E. Hudnell, III
`Lewis E. Hudnell, III
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`4
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`Case Nos. 3:22-cv-03199-JD, 3:22-cv-03202-JD; 3:21-cv-9773-JD
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