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)
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
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Attorneys for Defendant
7 MOSES & SINGER, LLP
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IN THE 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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13 E-PASS TECHNOLOGIES, INC., a Delaware
Corporation,
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Plaintiff,
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v.
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MOSES & SINGER, LLP, a New York Limited
17 Partnership; STEPHEN N. WEISS, ESQ., an
Individual; and DOES 1 through 59, inclusive,
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Defendants.
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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
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Pursuant to Local Rules 6-1 and 6-2, Plaintiff E-Pass Technologies, Inc. (“E-Pass”) and
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Defendants Moses & Singer LLP and Stephen N. Weiss (collectively the “Parties”), jointly
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stipulate as follows:
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WHEREAS, the Court issued and filed its Order on the Parties Joint Stipulation For
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Extended Time To File Amended Complaint And Briefing Schedule On Motions in this action
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on February 8, 2012 (Document No. 138) (“Order”);
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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
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CASE NO.: 3:09-CV-05967-EMC
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WHEREAS, the Order sets a further deadline for the filing of any venue motion by
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Defendants and the filing of Plaintiff’s motion for partial summary judgment of statute of
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limitations issues on February 17, 2012, with a briefing schedule and hearing date on all such
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motions set for March 23, 2012;
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WHEREAS, the Parties seek to further extend the current deadlines for Plaintiff to file any
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amended complaint and for the filing, briefing and hearing on any motions that are the subject of
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the Order by an additional period of two weeks for each of the deadlines set in the Order so that the
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Parties may continue to focus on exploring the informal resolution of the claims in this matter;
THEREFORE, the Parties jointly stipulate as follows:
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The last day for Plaintiff to file any further Amended Complaint in this action shall be
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extended from February 14, 2012 to February 28, 2012;
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The filing deadline for Defendants to file any venue motion and for Plaintiff to file any
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motion for partial summary adjudication of the statute of limitations issue shall be extended
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from February 17, 2012 to March 2, 2012;
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The opposition briefs to any venue motion filed by Defendants or motion for partial
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summary adjudication of the statute of limitations issue filed by Plaintiff shall be filed on
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March 16, 2012;
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The reply briefs in support of any venue motion filed by Defendants or motion for
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partial summary adjudication of the statute of limitations issue filed by Plaintiff shall be filed
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on March 23, 2012;
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The hearing date on any venue motion filed by Defendants or motion for partial
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summary adjudication of the statute of limitations issue filed by Plaintiff and further case status
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conference shall be continued from March 23, 2012 to April 6, 2012 at 1:30 PM.
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///
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///
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///
DM1\3121747.1
JOINT STIPULATION
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CASE NO.: 3:09-CV-05967-EMC
1 Dated: February 14, 2012
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DUANE MORRIS LLP
By:
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Attorneys for Defendants
MOSES & SINGER, LLP and
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/s/ Richard D. Hoffman
Richard D. Hoffman
Robert M. Fineman
Dated: February 14, 2012
LONG & LEVIT LLP
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By:
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/s/ Jessica MacGregor
Joseph McMonigle
Jessica MacGregor
Attorneys for Defendant
STEPHEN N. WEISS, ESQ.
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Dated: February 14, 2012
ROSEN SABA, LLP
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By:
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/s/ James R. Rosen
James R. Rosen
Ryan L. Saba
Attorneys for Plaintiff
E-PASS TECHNOLOGIES, INC.
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DM1\3121747.1
JOINT STIPULATION
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CASE NO.: 3:09-CV-05967-EMC
[PROPOSED] ORDER
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Based on the parties' Joint Stipulation, pursuant to Local Rules 6-1 and 6-2, and good cause
4 appearing,
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IT IS ORDERED that
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(1)
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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
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for partial summary adjudication of the statute of limitations issue filed by Plaintiff shall be
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filed and served on March 23, 2012;
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(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.
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dwa
Judge E
ER
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A
H
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FO
RT
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hen
rd M. C
NO
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R NIA
_____________________________
Honorable Edward DERED
R M. Chen
Judge ofS SO O States District Court,
I the United
IT
Northern District of California
LI
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UNIT
ED
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RT
U
O
2/16/12
21 Dated ___________
S
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S DISTRICT
TE
C
TA
N
F
D IS T IC T O
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DM1\3121747.1
JOINT STIPULATION
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CASE NO.: 3:09-CV-05967-EMC
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