United States Small Business Administration v. Rocket Ventures II, L.P. et al

Filing 70

STIPULATION AND ORDER RE 69 TO EXTEND TIME TO FILE OPPOSITION TO MOTION FOR SUMMARY JUDGMENT. Signed by Judge Jeffrey S. White on 5/21/12. (cl, COURT STAFF) (Filed on 5/21/2012)

Case3:10-cv-04425-JSW Document69 Filed05/17/12 Page1 of 3

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COOLEY LLP
GORDON C. ATKINSON (122401)
([e-mail])
ABIGAIL E. PRINGLE (272548)
([e-mail])
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants
ROCKET VENTURES II, L.P.; ROCKET VENTURES II CEO
FUND, L.P.; and ROCKET VENTURES SBIC PARTNERS,
LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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UNITED STATES SMALL BUSINESS
ADMINISTRATION in its capacity as Receiver
for ROCKET VENTURES II SBIC, L.P.,

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Plaintiff,
v.
ROCKET VENTURES II, L.P., a California
limited partnership; ROCKET VENTURES II
CEO FUND, L.P., a California limited
partnership; and ROCKET VENTURES SBIC
PARTNERS, LLC, a Delaware limited liability
company; Cordusio Societa Fiduciaria Per Azioni
Lozia Federico; Kenneth W. & Melissa Baldwin;
Paul Cantwell; Peter Ayrton Cheese; Yves
Derville; Richard S. Cuccioli; Alistair Anderson
Donald; Philippe Gire; Jean-Claude Guez; Joseph
Hawes & Christopher Eyden; Alan John Healey;
Craig Foster Heimark; David E. Kropp; Gregory
Charles Meekings; Michele Liberato; Fred
Cucchi; ValorLife; Alberto Gandini; Rijete Pty.
Ltd.; Christopher Stainton; Tyna Development;
Thomas Tynan; Patrice Vinet; Hahei Limited;
Michael Saunier; Michel Roujansky; Nigel
Backwith; Justine Lumb; Andrew Middleton;
Ajmair Singh Bhullar; Estate of Grant A. Dove;
Luca Casiraghi; David Mather,

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Case No. CV-10-4425 JSW
STIPULATION AND [PROPOSED] ORDER
BETWEEN PLAINTIFF RECEIVER AND
DEFENDANTS ROCKET VENTURES II,
L.P., ROCKET VENTURES II CEO FUND,
L.P., AND ROCKET VENTURES SBIC
PARTNERS, LLC TO EXTEND TIME TO
FILE OPPOSITION TO MOTION FOR
SUMMARY JUDGMENT

Defendants.

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COOLEY LLP
ATTO RNEY S AT LAW
SAN FRA NCI S CO

1270051/SF

1.

STIPULATION AND [PROPOSED] ORDER TO
EXTEND TIME TO FILE OPPOSITION TO SUJ
MOTION (CASE NO. CV-10-4425-JSW)

Case3:10-cv-04425-JSW Document69 Filed05/17/12 Page2 of 3

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Defendants Rocket Ventures II, L.P., Rocket Ventures II CEO Fund, L.P., and Rocket

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Ventures SBIC Partners, LLC (“Defendants”) and Plaintiff United States Business Administration

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in its capacity as Receiver for Rocket Ventures II SBIC, L.P. (“Plaintiff Receiver”), by and

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through their respective counsel of record, hereby stipulate and agree as follows:

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WHEREAS, Plaintiff Receiver filed a motion for summary judgment on April 3, 2012;

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WHEREAS, Defendants’ opposition to the motion for summary judgment is presently due

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on May 18, 2012;

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WHEREAS, the Parties agree to permit additional time for Defendants to respond to

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Plaintiff Receiver’s motion and agree that such additional time to respond shall not affect the due

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date of Plaintiff Receiver’s reply nor the date of the hearing on the motion;

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FOR THE REASONS set forth above:

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IT IS HEREBY STIPULATED AND ORDERED THAT:

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1.

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extended to and including May 22, 2012 and shall be filed no later than 5:00 p.m. (PDT);

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Defendants’ opposition to Plaintiff Receiver’s motion for summary judgment is

2.

Plaintiff Receiver’s reply in support of its motion for summary judgment due on

May 29, 2012 will remain the same; and

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3.

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the same.

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The hearing on the motion for summary judgment on June 15, 2012 will remain

COOLEY LLP
ATTO RNEY S AT LAW
SAN FRA NCI S CO

1270051 /SF

2.

STIPULATION AND [PROPOSED] ORDER TO
EXTEND TIME TO FILE OPPOSITION TO SUJ
MOTION (CASE NO. CV-10-4425-JSW)

Case3:10-cv-04425-JSW Document69 Filed05/17/12 Page3 of 3

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SO STIPULATED.

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Dated: May 17, 2012

COOLEY LLP

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By: /s/ Gordon C. Atkinson
Gordon C. Atkinson

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Attorneys for Defendants
ROCKET VENTURES II, L.P., ROCKET
VENTURES II CEO FUND, L.P. and ROCKET
VENTURES SBIC PARTNERS, LLC

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Dated: May 17, 2011

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SCHNADER HARRISON SEGAL & LEWIS
LLP

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By: /s/ T. Scott Tate
T. Scott Tate

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Attorneys for Plaintiff
UNITED STATES SMALL BUSINESS
ADMINISTRATION in its capacity as Receiver
for ROCKET VENTURES II SBIC, L.P.

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Filer’s Attestation re signatures: Gordon C. Atkinson hereby attests that concurrence in the filing
of this document has been obtained.
ORDER

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IT IS SO ORDERED:

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Dated: May ___, 2012
Honorable Jeffrey S. White
United States District Court Judge

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COOLEY LLP
ATTO RNEY S AT LAW
SAN FRA NCI S CO

1270051 /SF

3.

STIPULATION AND [PROPOSED] ORDER TO
EXTEND TIME TO FILE OPPOSITION TO SUJ
MOTION (CASE NO. CV-10-4425-JSW)