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`
`
`
`
`Juanita Brooks (SBN 75934) brooks@fr.com
`Roger A. Denning (SBN 228998) denning@fr.com
`Jason W. Wolff (SBN 215819) wolff@fr.com
`Michael A. Amon (SBN 226221) amon@fr.com
`FISH & RICHARDSON P.C.
`12860 El Camino Real, Suite 400
`San Diego, CA 92130
`Tel: (858) 678-5070 / Fax: (858) 678-5099
`
`Lawrence Jarvis (pro hac vice)
`FISH & RICHARDSON P.C.
`1180 Peachtree St., NE
`21st Floor
`Atlanta, GA 30309
`Tel: (404) 891-5005 / Fax: (404) 892-5002
`
`Attorneys for Plaintiff & Counter-Defendant
`FINJAN LLC
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`SOUTHERN DISTRICT OF CALIFORNIA
`
`
`Case No. 17-cv-0183 CAB (BGS)
`
`
`DECLARATION OF MICHAEL A.
`
`AMON IN SUPPORT OF PARTIES’
`
`JOINT MOTION TO AMEND CASE
`
`SCHEDULE
`
`
`District Judge: Hon. Cathy Ann
`Bencivengo
`Magistrate Judge: Hon. Bernard G.
`Skomal
`
`
`
`
`
`FINJAN LLC,
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` Plaintiffs,
`
`v.
`
`
`ESET, LLC and ESET SPOL. S.R.O.,
`
`
`
`
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` Defendants.
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`
`
`
`
`AND RELATED COUNTERCLAIMS
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`DECLARATION OF AMON ISO JT MOTION
`TO AMEND CASE SCHEDULE
`Case No. 17-cv-0183 CAB (BGS)
`
`
`
`Case 3:17-cv-00183-CAB-BGS Document 850-1 Filed 01/13/21 PageID.40528 Page 2 of 4
`
`
`
`I, Michael A. Amon, declare as follows:
`
`1.
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`I am a principal of Fish & Richardson P.C., counsel of record in this
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`action for Plaintiff Finjan LLC (“Finjan”). I am a member of the Bar of the State of
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`California and of this Court. Unless otherwise noted, I have personal knowledge of
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`the matters stated in this declaration and would testify truthfully to them if called upon
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`to do so.
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`2.
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`I make this declaration in support of the Parties’ Joint Motion to Amend
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`Case Schedule.
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`3.
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`One of Finjan’s experts in the case has contracted and is suffering from
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`the illness caused by the COVID-19 virus.1 That illness includes fever, difficulty
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`breathing, lethargy, and a general inability to perform work.
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`4.
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`On information provided by Defendant ESET’s counsel, “the situation
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`[regarding the COVID-19 pandemic] in Slovakia has deteriorated significantly over
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`the past few weeks and that [sic] hospitals are close to collapse.” As I understand
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`from ESET’s counsel, this deterioration directly impacts ESET’s witnesses, including
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`their ability to participate in aspects of this case.
`
`I declare under penalty of perjury under the laws of the United States that the
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`forgoing is true and correct.
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`Executed at San Diego, California on January 13, 2021.
`
` /s/ Michael A. Amon
`Michael A. Amon
`amon@fr.com
`
`
`
`
`
`
`
` 1
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` Because of privacy concerns, Finjan does not identify the particular expert in this
`public filing. To the extent the Court so requires, Finjan can submit his name in a
`confidential manner.
`
`1
`DECLARATION OF AMON ISO JT MOTION
`TO AMEND CASE SCHEDULE
`Case No. 17-cv-0183 CAB (BGS)
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`Case 3:17-cv-00183-CAB-BGS Document 850-1 Filed 01/13/21 PageID.40529 Page 3 of 4
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`
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`ECF ATTESTATION
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`I, Michael A. Amon, am the ECF User who identification and password are
`
`being used to electronically file this JOINT MOTION TO AMEND CASE
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`SCHEDULE. In accordance with the Electronic Case Filing Administrative Policies
`
`and Procedures Manual 2(f)(4), concurrence in and authorization of the filing of this
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`document has been obtained from the counsel for defendants, and Fish & Richardson
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`P.C. shall maintain records to support this concurrence for subsequent production for
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`the Court if so ordered or for inspection upon request by a party.
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`2
`DECLARATION OF AMON ISO JT MOTION
`TO AMEND CASE SCHEDULE
`Case No. 17-cv-0183 CAB (BGS)
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`Case 3:17-cv-00183-CAB-BGS Document 850-1 Filed 01/13/21 PageID.40530 Page 4 of 4
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`
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above and
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`foregoing document has been served on January 13, 2021, to all counsel of record
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`who are deemed to have consented to electronic service via the Court’s CM/ECF
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`system per Civil Local Rule 5.4. Any other counsel of record will be served by
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`electronic mail, facsimile and/or overnight delivery.
`
`
`
`/s/ Michael A. Amon
`Michael A. Amon
`amon@fr.com
`
`3
`DECLARATION OF AMON ISO JT MOTION
`TO AMEND CASE SCHEDULE
`Case No. 17-cv-0183 CAB (BGS)
`
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