1- DECLARATION OF GABRIELLE D. RICHARDS

IN SUPPORT OF PLAINTIFF’S RESPONSE MEMORANDUM

IN OPPOSITION TO DEFENDANT’S MOTION TO EXTEND 

DISCOVERY DEADLINE

LEGAL126565963.1

Perkins Coie LLP

1120 N.W. Couch Street, Tenth Floor

Portland, OR 97209-4128

Phone: 503.727.2000

Fax: 503.727.2222

Erick J. Haynie, OSB No. 982482

EHaynie@perkinscoie.com

Gabrielle D. Richards, OSB No. 114992

GRichards@perkinscoie.com

PERKINS COIE LLP

1120 N.W. Couch Street, Tenth Floor

Portland, OR 97209-4128

Telephone: 503.727.2000

Facsimile: 503.727.2222

Attorneys for Plaintiff

LNV Corporation

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

LNV CORPORATION, a Nevada 

corporation,

Plaintiff,

v.

DENISE SUBRAMANIAM,

Defendant.

Case No. 14-cv-01836-MO

DECLARATION OF

GABRIELLE D. RICHARDS

IN SUPPORT OF PLAINTIFF’S 

RESPONSE MEMORANDUM

IN OPPOSITION TO DEFENDANT’S 

MOTION TO EXTEND DISCOVERY 

DEADLINE

I, Gabrielle D. Richards, declare as follows:

1. I am an attorney with Perkins Coie LLP (“Perkins Coie”), counsel for LNV 

Corporation (“LNV”), the plaintiff in the above-captioned action.

2. I am over the age of 18 and have personal knowledge of the facts contained in this 

declaration, or I have gained knowledge of them from my review of the business records of 

Perkins Coie that are maintained in the ordinary course of business as they relate to this action.

Case 3:14-cv-01836-MO Document 58 Filed 06/19/15 Page 1 of 4
2- DECLARATION OF GABRIELLE D. RICHARDS

IN SUPPORT OF PLAINTIFF’S RESPONSE MEMORANDUM

IN OPPOSITION TO DEFENDANT’S MOTION TO EXTEND 

DISCOVERY DEADLINE

LEGAL126565963.1

Perkins Coie LLP

1120 N.W. Couch Street, Tenth Floor

Portland, OR 97209-4128

Phone: 503.727.2000

Fax: 503.727.2222

3. Attached hereto as Exhibit A is a true and correct copy of a letter I sent to

Defendant on January 21, 2015 containing a link to the Local Rules.

4. Attached hereto as Exhibit B is a true and correct copy of my email 

correspondence with Defendant regarding extending the discovery deadline. As this 

correspondence shows, Defendant contacted me on May 27, 2015 seeking to “extend the 

discovery deadlines to reflect what we would have had if the need for a medical stay had not 

occurred.” I responded less than three hours later, proposing July 13, 2015 as the new deadline 

for the completion of discovery, filing of dispositive motions and filing of the joint alternate 

dispute resolution report. I did not receive a response from Defendant to my May 27, 2015 

email. Because we were nearing the June 8 deadlines, I sent a second email to Defendant on 

June 2, 2015. I did not receive a response to this email, either.

5. Having not heard from Defendant, and needing to move forward with filing my 

client’s motion for summary judgment, I telephoned Defendant on June 5 in an attempt to confer 

regarding the summary judgment motion and the joint alternate dispute resolution report, both of 

which were due on June 8, 2015. Defendant told me that her daughter had recently given birth 

and that she preferred to talk on June 8. I agreed to call her the morning of June 8.

6. I called Defendant on the morning of June 8 to confer regarding the motion for 

summary judgment and the joint alternate dispute resolution report. When Defendant began 

discussing the “June 17” deadline extension, I told Defendant that, having received no response 

to repeated emails, my client was no longer able to stipulate to an extension and had no choice 

but to move forward with its summary judgment motion. During our call, Defendant told me 

that a July deadline was insufficient.

7. During our June 8 call, Defendant specifically referenced my client’s proposed 

deadline extension but also represented that she had not received my emails regarding the 

proposed deadline extension.

Case 3:14-cv-01836-MO Document 58 Filed 06/19/15 Page 2 of 4
3- DECLARATION OF GABRIELLE D. RICHARDS

IN SUPPORT OF PLAINTIFF’S RESPONSE MEMORANDUM

IN OPPOSITION TO DEFENDANT’S MOTION TO EXTEND 

DISCOVERY DEADLINE

LEGAL126565963.1

Perkins Coie LLP

1120 N.W. Couch Street, Tenth Floor

Portland, OR 97209-4128

Phone: 503.727.2000

Fax: 503.727.2222

8. Attached hereto as Exhibit C is a true and correct of email correspondence with 

the Court regarding the June 8 deadlines.

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

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

Dated: June 19, 2015.

/s/ Gabrielle D. Richards

Gabrielle D. Richards

Case 3:14-cv-01836-MO Document 58 Filed 06/19/15 Page 3 of 4
PAGE 1- CERTIFICATE OF SERVICE

LEGAL126565963.1

Perkins Coie LLP

1120 N.W. Couch Street, Tenth Floor

Portland, OR 97209-4128

Phone: 503.727.2000

Fax: 503.727.2222

CERTIFICATE OF SERVICE

I certify that I served the foregoing DECLARATION OF GABRIELLE D. 

RICHARDS on 

Denise Subramaniam

13865 SW Walker Rd.

Beaverton, OR 97005

Defendant

by depositing a copy in the U.S. Mail in a sealed postage-prepaid envelope and deposited with 

the United States Postal Service at Portland, Oregon on the date set forth below.

DATED: June 19, 2015 /s/ Gabrielle D. Richards

Gabrielle D. Richards, OSB No. 114992

GRichards@perkinscoie.com

Attorneys for Plaintiff

LNV Corporation

Case 3:14-cv-01836-MO Document 58 Filed 06/19/15 Page 4 of 4