E-Pass Technologies, Inc. v. Moses & Singer, LLP et al

Filing 140

STIPULATION AND ORDER re 139 STIPULATION WITH PROPOSED ORDER (JOINT - for Further Extending Time to File Amended Complaint and Briefing Schedule on Motions) filed by Moses & Singer, LLP Motions due by 2/28/2012. Status Report due by 3/30/2012. Motion Hearing set for 4/6/2012 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Hon. Edward M. Chen. Status Conference reset for 4/6/2012 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Hon. Edward M. Chen.. Signed by Judge Edward M. Chen on 2/16/12. (bpf, COURT STAFF) (Filed on 2/16/2012)

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1 Richard D. Hoffman (SBN 76799) Robert M. Fineman (SBN 188211) 2 DUANE MORRIS LLP Spear Tower 3 One Market Plaza, Suite 2200 San Francisco, CA 94105-1127 4 Telephone: 415.957.3000 Facsimile: 415.957.3001 RHoffman@duanemorris.com 5 E-mail: RMFineman@duanemorris.com 6 Attorneys for Defendant 7 MOSES & SINGER, LLP 8 9 IN THE UNITED STATES DISTRICT COURT 10 FOR THE NORTHERN DISTRICT OF CALIFORNIA 11 SAN FRANCISCO DIVISION 12 13 E-PASS TECHNOLOGIES, INC., a Delaware Corporation, 14 Plaintiff, 15 v. 16 MOSES & SINGER, LLP, a New York Limited 17 Partnership; STEPHEN N. WEISS, ESQ., an Individual; and DOES 1 through 59, inclusive, 18 Defendants. 19 Case No.: 3:09-cv-05967-EMC JOINT STIPULATION FOR FURTHER EXTENDING TIME TO FILE AMENDED COMPLAINT AND BRIEFING SCHEDULE ON MOTIONS ORDER Courtroom: 5, 17th Floor Judge: Complaint Filed: Trial Date: Hon. Edward M. Chen December 21, 2009 February 4, 2013 20 21 Pursuant to Local Rules 6-1 and 6-2, Plaintiff E-Pass Technologies, Inc. (“E-Pass”) and 22 Defendants Moses & Singer LLP and Stephen N. Weiss (collectively the “Parties”), jointly 23 stipulate as follows: 24 WHEREAS, the Court issued and filed its Order on the Parties Joint Stipulation For 25 Extended Time To File Amended Complaint And Briefing Schedule On Motions in this action 26 on February 8, 2012 (Document No. 138) (“Order”); 27 28 WHEREAS, the Order sets a deadline for the last day for Plaintiff to amend the complaint on February 14, 2012; DM1\3121747.1 JOINT STIPULATION 1 CASE NO.: 3:09-CV-05967-EMC 1 WHEREAS, the Order sets a further deadline for the filing of any venue motion by 2 Defendants and the filing of Plaintiff’s motion for partial summary judgment of statute of 3 limitations issues on February 17, 2012, with a briefing schedule and hearing date on all such 4 motions set for March 23, 2012; 5 WHEREAS, the Parties seek to further extend the current deadlines for Plaintiff to file any 6 amended complaint and for the filing, briefing and hearing on any motions that are the subject of 7 the Order by an additional period of two weeks for each of the deadlines set in the Order so that the 8 Parties may continue to focus on exploring the informal resolution of the claims in this matter; THEREFORE, the Parties jointly stipulate as follows: 9 The last day for Plaintiff to file any further Amended Complaint in this action shall be 10 11 extended from February 14, 2012 to February 28, 2012; 12 The filing deadline for Defendants to file any venue motion and for Plaintiff to file any 13 motion for partial summary adjudication of the statute of limitations issue shall be extended 14 from February 17, 2012 to March 2, 2012; 15 The opposition briefs to any venue motion filed by Defendants or motion for partial 16 summary adjudication of the statute of limitations issue filed by Plaintiff shall be filed on 17 March 16, 2012; 18 The reply briefs in support of any venue motion filed by Defendants or motion for 19 partial summary adjudication of the statute of limitations issue filed by Plaintiff shall be filed 20 on March 23, 2012; 21 The hearing date on any venue motion filed by Defendants or motion for partial 22 summary adjudication of the statute of limitations issue filed by Plaintiff and further case status 23 conference shall be continued from March 23, 2012 to April 6, 2012 at 1:30 PM. 24 /// 25 /// 26 /// 27 /// 28 /// DM1\3121747.1 JOINT STIPULATION 2 CASE NO.: 3:09-CV-05967-EMC 1 Dated: February 14, 2012 2 DUANE MORRIS LLP By: 3 4 Attorneys for Defendants MOSES & SINGER, LLP and 5 6 /s/ Richard D. Hoffman Richard D. Hoffman Robert M. Fineman Dated: February 14, 2012 LONG & LEVIT LLP 7 By: 8 9 10 /s/ Jessica MacGregor Joseph McMonigle Jessica MacGregor Attorneys for Defendant STEPHEN N. WEISS, ESQ. 11 12 Dated: February 14, 2012 ROSEN SABA, LLP 13 By: 14 15 16 /s/ James R. Rosen James R. Rosen Ryan L. Saba Attorneys for Plaintiff E-PASS TECHNOLOGIES, INC. 17 18 19 20 21 22 23 24 25 26 27 28 DM1\3121747.1 JOINT STIPULATION 3 CASE NO.: 3:09-CV-05967-EMC [PROPOSED] ORDER 1 2 3 Based on the parties' Joint Stipulation, pursuant to Local Rules 6-1 and 6-2, and good cause 4 appearing, 5 IT IS ORDERED that 6 (1) 7 8 9 10 11 12 13 The last day for Plaintiff to file and serve any further Amended Complaint in this action shall be extended from February 14, 2012 to February 28, 2012; (2) The filing deadline for Defendants to file and serve any venue motion and for Plaintiff to file and serve any motion for partial summary adjudication of the statute of limitations issue shall be extended from February 17, 2012 to March 2, 2012; (3) The opposition briefs to any venue motion filed by Defendants or motion for partial summary adjudication of the statute of limitations issue filed by Plaintiff shall be filed and served on March 16, 2012; (4) The reply briefs in support of any venue motion filed by Defendants or motion 14 for partial summary adjudication of the statute of limitations issue filed by Plaintiff shall be 15 filed and served on March 23, 2012; 16 (5) The hearing date on any venue motion filed by Defendants or motion for partial 17 summary adjudication of the statute of limitations issue filed by Plaintiff and further case status 18 conference shall be continued from March 23, 2012 to April 6, 2012 at 1:30 PM. 19 dwa Judge E ER 27 A H 26 FO RT 25 hen rd M. C NO 24 R NIA _____________________________ Honorable Edward DERED R M. Chen Judge ofS SO O States District Court, I the United IT Northern District of California LI 23 UNIT ED 22 RT U O 2/16/12 21 Dated ___________ S 20 S DISTRICT TE C TA N F D IS T IC T O R C 28 DM1\3121747.1 JOINT STIPULATION 4 CASE NO.: 3:09-CV-05967-EMC

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