Farhang v. Indian institute of Technology Kharagpur et al

Filing 512

ORDER granting 510 STIPULATION re 508 Case Management Scheduling Order. Case Management Conference set for 5/9/2017 02:00 PM in Courtroom 2, 17th Floor, San Francisco. Case Management Statement due by 5/2/2017. Signed by Judge William H. Orrick on 04/03/2017. (jmdS, COURT STAFF) (Filed on 4/3/2017)

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I. NEEL CHATTERJEE (SBN 173985)
[e-mail]
MICHAEL T. JONES (SBN 661336)
[e-mail]
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025-1105
Tel.: [phone]
Fax.: [phone]
Attorneys for Defendant
INDIAN ISITUTE OF
TEHCNOLOGY, KHARAGPUR
[ADDITIONAL COUNSEL LISTED
ON SIGNATURE PAGE]

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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MANDANA D FARHANG, et al.,
Plaintiff,

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v.
INDIAN INSTITUTE OF TECHNOLOGY
KHARAGPUR, et al.,
Defendant.

Civil Action No. 3:08-cv-02658-WHO
STIPULATION AND ORDER
REQUESTING RESCHEDULING
OF CASE MANAGEMENT
CONFERENCE AND ORDER
Date:
April 11, 2017
Time:
2:00 p.m.
Judge: Honorable William H. Orrick

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STIPULATION AND ORDER REQUESTING RESCHEDULING OF CASE MANAGEMENT CONFERENCE
CASE NO. 3:08-CV-02658-WHO

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Pursuant to Federal Rule of Civil Procedure 6(b) and Local Rules 6-1(b) and 6-2, Defendants

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INDIAN INSTITUTE OF TECHNOLOGY KHARAGPUR (“IIT”), through their undersigned

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counsel, hereby file the following request to postpone the Case Management Conference scheduled

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for April 11, 2017 at 2:00 p.m. for twenty four (24) days until May 5, 2017 at 2:00 p.m., or the

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Court’s earliest available date thereafter. In support of this request, the Defendants submit as

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follows:

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WHEREAS, on March 23, 2017, the Court issued an order scheduling a case management
conference for April 11, 2017 at 2:00 p.m. (Dkt. 508);
WHEREAS, in February 2017, Defendant’s counsel changed law firms and is currently

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seeking to obtain the files from the case from the previous firm. Defendant requires additional time

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to prepare for the Case Management Conference in order to adequately review and transfer all

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records that exist in the case, as well as to meet and confer on Case Management issues. An

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additional twenty four (24) days should permit sufficient time for the parties to attend to these

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matters;

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WHEREAS, on February 22, 2017, Defendant filed a change of counsel, and therefore

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believes rescheduling the case management conference is appropriate. Defendant requires additional

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time to prepare for the Case Management Conference in order to adequately review all records that

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exist in the case. This will permit Defendant to meaningfully participate in the Case Management

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Conference. The parties require additional time for counsel to meet and confer to prepare a joint case

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management statement;

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WHEREAS, counsel for Defendant is unavailable during the currently scheduled case
management conference date of April 11, 2017;

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WHEREAS, rescheduling this Case Management Conference will allow both parties

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additional time to meaningfully meet and confer regarding case management issues and Plaintiffs’

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counsel has indicated they are not opposed to the rescheduling of the Case Management Conference

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or to an extension of time for submission of a joint case management statement;

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WHEREAS, no Party will be prejudiced by the relief requested in the stipulation and there
will be no changes to the case schedule in existence prior to the entry of this stipulation; and
STIPULATION AND ORDER REQUESTING RESCHEDULING OF CASE MANAGEMENT CONFERENCE
CASE NO. 3:08-CV-02658-WHO

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WHEREAS, all Parties’ claims and defenses are expressly preserved and not waived by
entering into this stipulation.

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, between the Parties

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and Defendant respectfully moves the Court that the Case Management Conference shall be moved

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from April 11, 2017 at 2:00 p.m. to May 5, 2017 at 2:00 p.m., or the soonest date thereafter that the

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Court is available, and that the date for the submission of the joint case management statement will

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be moved from April 4, 2017 to April 28, 2017.

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Respectfully submitted,

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By their attorneys,

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Dated: March 29, 2017

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/s/ I. Neel Chatterjee
I. Neel Chatterjee (SBN 173985)
[e-mail]
Michael T. Jones (SBN 661336)
[e-mail]
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025-1105
Tel.: [phone]
Fax.: [phone]

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Attorneys for Defendant
INDIAN ISITUTE OF
TEHCNOLOGY, KHARAGPUR

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Respectfully submitted,

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By their attorneys,

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Dated: March 29, 2017

/s/ Sanjiv N. Singh
Sanjiv N. Singh (SBN 193525)
[e-mail]
SANJIV N. SINGH,
A PROFESSIONAL LAW CORP.
21 Columbus Avenue, Suite 205
San Francisco, CA 94111
Tel.: [phone]
Fax.: [phone]
Micah R. Jacobs (SBN 174630)
[e-mail]
388 Market Street, Suite 1300

STIPULATION AND ORDER REQUESTING RESCHEDULING OF CASE MANAGEMENT CONFERENCE
CASE NO. 3:08-CV-02658-WHO

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San Francisco, CA 94111
Tel.: [phone]
Fax.: [phone]
Attorneys for Plaintiffs
M.A. MOBILE LTD and
MANDANA D. FARHANG

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STIPULATION AND ORDER REQUESTING RESCHEDULING OF CASE MANAGEMENT CONFERENCE
CASE NO. 3:08-CV-02658-WHO

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ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED. The Case Management Conference
is set for May 9, 2017 at 2:00 p.m.

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DATED: April 3, 2017

_____________________________________
HONORABLE WILLIAM H. ORRICK
United States District Judge

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STIPULATION AND ORDER REQUESTING RESCHEDULING OF CASE MANAGEMENT CONFERENCE
CASE NO. 3:08-CV-02658-WHO