Berkeley Law

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Berkeley Law
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posted:
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Berkeley Law & Technology Group, LLP v. Cool Doc.









Johnathan E. Mansfield, OSB #055390

Email jmansfield@schwabe.com

Tiffany A. Harris, OSB #023187

Email tharris@schwabe.com

Schwabe, Williamson & Wyatt, P.C.

Pacwest Center

1211 SW 5th Ave., Suite 1900

Portland, OR 97204

Telephone 503.222.9981

Fax 503.796.2900

Of Attorneys for Defendant, Kenneth J. Cool









IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON







BERKELEY LAW & TECHNOLOGY No. CV 07-709 BR

GROUP, LLP, an Oregon limited liability

partnership,

DECLARATION OF TIFFANY A. HARRIS

Plaintiff, IN SUPPORT OF DEFENDANT’S

UNOPPOSED MOTION TO EXTEND

TIME TO ANSWER FIRST AMENDED

vs. COMPLAINT

KENNETH J. COOL, a Colorado

resident,



Defendant.



I, Tiffany A. Harris, do declare and say that under the penalty of perjury and the laws of



the State of Oregon that the following is true.



1. I am an associate at the law firm of Schwabe Williamson & Wyatt and one of the



attorneys representing defendant Kenneth Cool in this matter.



2. I have conferred with plaintiff's counsel Lawrence Reichman, and he does not



oppose defendant's request for an extension of 14 days to appear and Answer plaintiff's First



Amended Complaint, no later than June 25, 2007.

Page 1 - DECLARATION OF TIFFANY A. HARRIS IN SUPPORT SCHWABE, WILLIAMSON & WYATT, P.C.

Attorneys at Law

Pacwest Center

OF DEFENDANT’S UNOPPOSED MOTION TO EXTEND 1211 SW 5th Ave., Suite 1900

Portland, OR 97204

TIME TO ANSWER FIRST AMENDED COMPLAINT Telephone 503.222.9981

PDX/117213/154514/TH/1555220.1





Dockets.Justia.com

3. The parties are engaged in efforts to settle this matter before the case is placed at



issue. The requested extension of time will facilitate these efforts.



I hereby declare that the above statement is true to the best of my knowledge and



belief and I understand that it is made for use as evidence in court and is subject to penalty



for perjury.



Dated this 7th day of June, 2007.





__/s/ Tiffany A. Harris____________

Tiffany A. Harris









Page 2 - DECLARATION OF TIFFANY A. HARRIS IN SUPPORT SCHWABE, WILLIAMSON & WYATT, P.C.

Attorneys at Law

Pacwest Center

OF DEFENDANT’S UNOPPOSED MOTION TO EXTEND 1211 SW 5th Ave., Suite 1900

Portland, OR 97204

TIME TO ANSWER FIRST AMENDED COMPLAINT Telephone 503.222.9981

PDX/117213/154514/TH/1555220.1


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