STIPULATION AND [PROPOSED] ORDER
RE DECLARATIONS PURSUANT TO
GOOGLE’S RULE 11 MOTION
-1-
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
STIPULATION AND [PROPOSED]
ORDER RE DECLARATIONS
SUBMITTED IN CAMERA PER
JANUARY 22, 2007 COURT ORDER
Subject to approval of this Court, the parties hereby stipulate to the following:
1.
On October 20, 2006, Defendant Google, Inc. (“Google”) filed a motion for
sanctions against Plaintiff KinderStart.com LLC (“KinderStart”) and its legal counsel Gregory J.
Yu for sanctions under Rule 11 (“Rule 11 Motion”) of the Federal Rules of Civil Procedure. On
January 22, 2007, the Court issued an order (the “Rule 11 Order”) that Gregory J. Yu submit to
the Court in camera declarations (“Rule 11 Declarations”) to support certain allegations in the
Second Amended Complaint by February 6, 2007. The parties agree, subject to Court approval,
that the original deadline of February 6, 2007 be extended by 14 calendar days to February 20,
2007 for submitting Rule 11 Declarations pursuant to the Rule 11 Order. KinderStart’s legal
counsel has communicated to Google’s legal counsel that one of the Rule 11 declarants is out of
the United States until February 8, 2007. Accordingly, Google is willing to stipulate to an
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 86 Filed 02/06/2007 Page 1 of 5
STIPULATI