PLAINTIFFS’ MOTION UNDER L.R. 7-7
TO CONTINUE CCP § 425.16 MOTION
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Case No. C 06-2057 JF
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
KINDERSTART.COM LLC, a California
limited liability company, on behalf of itself and
all others similarly situated,
Plaintiffs,
v.
GOOGLE, INC., a Delaware corporation,
Defendant.
Case No. C 06-2057 JF
PLAINTIFF’S ADMINISTRATIVE
MOTION UNDER LOCAL RULE 7-7(b)
TO CONTINUE DEFENDANT’S
SPECIAL MOTION TO STRIKE
PURSUANT TO CCP § 425.16
CALENDARED FOR JUNE 30, 2006
FACTUAL AND PROCEDURAL BACKGROUND
On May 2, 2006, Defendant Google noticed and filed its Special Motion (“Anti-SLAPP
Motion”) under California Code of Civil Procedure (CCP § 425.16) to strike Counts One, Eight
and Nine of the First Amended Class Action Complaint (“FACAC”) of Plaintiff KinderStart.com
LLC (“KSC”). Count Eight is for Google’s defamation and libel by means of PageRank™
devaluation of websites. During the week of June 2, 2006, Plaintiff verbally informed Defendant
of its need for discovery in connection with the Anti-SLAPP Motion. On June 9, 2006, Plaintiff
KSC timely filed its opposition with a conditional request for a continuance of the hearing and
discovery by KSC of facts exclusively within Google’s control essential to KSC’s case in chief
on Count Eight. On June 13, 2006, Plaintiff delivered a list of information required of Google to
form the factual foundation for Plaintiffs’ burden to demonstrate the probability of prevailing on
Gregory J. Yu (State Bar No. 133955)
GLOBAL LAW GROUP
2015 Pioneer Court, Suite P-1
San Mateo, CA 94403
Telephone: (650) 570-4140
Facsimile: (650) 570-4142
E-mail: glgroup [at] inreach [dot] com
Attorney for Plaintiffs and Proposed Class and Subclasses
Case 5:06-cv-02057-JF Document 31 Filed 06/16/2006 Page 1 of 3
Kinderstart.Co