Jackson v. Fischer et al

Filing 60

ORDER GRANTING 59 Stipulation TO EXCEED PAGE LIMITS ESTABLISHED BY THE COURTS CIVIL STANDING ORDERS. Signed by Judge Jeffrey S. White on 1/5/12. (jjoS, COURT STAFF) (Filed on 1/5/2012)

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Case3:11-cv-02753-JSW Document59 Filed01/04/12 Page1 of 5 1 2 3 4 5 The Law of Offices of Tom Chia-Kai Wang Tom Chia-Kai Wang (SBN 269050) 117 West 9th St., Suite 206 Los Angeles, CA 90015 Telephone: (213) 290-0930 Facsimile: (213) 622-0335 Attorneys for Defendants Chetan Narsude, Mani Kulasooriya, Monvia LLC and New Moon LLC 6 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 SAN FRANCISCO DIVISION 10 11 SUZANNE D. JACKSON, 12 13 14 15 16 17 18 19 20 21 Plaintiff, v. WILLIAM FISCHER; JON SABES; STEVEN SABES; DAVID GOLDSTEEN; MARVIN SIEGEL; BRIAN CAMPION; LONNIE BROOKBINDER; CHETAN NARSUDE; MANI KULASOORIYA; JOSHUA ROSEN; UPPER ORBIT, LLC; SPECIGEN, INC.; PEER DREAMS INC.; NOTEBOOKZ INC.; ILEONARDO.COM INC.; NEW MOON LLC; MONVIA LLC; and SAZANI BEACH HOTEL, Case No. 3:11-cv-02753-JSW STIPULATION AND [PROPOSED] ORDER GRANTING LEAVE TO EXCEED PAGE LIMITS ESTABLISHED BY THE COURT’S CIVIL STANDING ORDERS Defendants. 22 23 24 25 26 27 28 STIPULATION AND [PROPOSED] ORDER GRANTING LEAVE TO EXCEED PAGE LIMITS ESTABLISHED BY THE COURT’S CIVIL STANDING ORDERS Case3:11-cv-02753-JSW Document59 Filed01/04/12 Page2 of 5 1 2 3 Plaintiff Suzanne Jackson and Defendants Chetan Narsude, Mani Kulasooriya, Monvia LLC and New Moon LLC (collectively “Defendants”), by and through their counsel, and subject to the Court’s approval, stipulate as follows: 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 WHEREAS, Plaintiff filed a First Amended Complaint (“FAC”) on December 5, 2011; WHEREAS, the FAC asserts purported federal securities fraud and common law claims related to Plaintiff's investments; WHEREAS, the FAC alleges, inter alia, that Defendants engaged in a comprehensive scheme to defraud Plaintiff in violation of the Securities Exchange Act of 1934 and the Securities Act of 1933 and by failing to provide and failing to disclose material facts, which purportedly constitute common law fraud; WHEREAS, the parties agree that the FAC’s scope and complexity warrant a modest increase in the page limits imposed by this Court’s Civil Standing Orders for Defendants’ opening brief and Plaintiff’s opposition brief to Defendants’ motion to dismiss, but that the page limit for Defendants’ reply brief shall remain 15 pages; NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED BY AND BETWEEN THE PARTIES, subject to the Court’s approval, that: 1. Defendants’ memorandum of law in support of their motion to dismiss shall not exceed 25 pages; and 2. Plaintiff's memorandum of law in opposition to Defendants’ motion to dismiss shall not exceed 25 pages. 22 23 Dated: January 4, 2012 KAUFMAN LLC 24 25 By: /s/ Alan H. Kaufman 26 Alan H. Kaufman 27 28 Attorneys for Plaintiff Suzanne D. Jackson -2STIPULATION AND [PROPOSED] ORDER GRANTING LEAVE TO EXCEED PAGE LIMITS ESTABLISHED BY THE COURT’S CIVIL STANDING ORDERS Case3:11-cv-02753-JSW Document59 Filed01/04/12 Page3 of 5 1 Dated: January 4, 2012 THE LAW OFFICES OF TOM CHIA-KAI WANG 2 3 By: /s/ Tom Chia Kai Wang 4 Tom Chia Kai Wang 5 6 7 Attorneys for Defendants Chetan Narsude, Mani Kulasooriya, Monvia LLC and New Moon LLC 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3STIPULATION AND [PROPOSED] ORDER GRANTING LEAVE TO EXCEED PAGE LIMITS ESTABLISHED BY THE COURT’S CIVIL STANDING ORDERS Case3:11-cv-02753-JSW Document59 Filed01/04/12 Page4 of 5 1 2 3 4 5 [PROPOSED] ORDER Having reviewed the above stipulation, IT IS HEREBY ORDERED that the page limits for the motion to dismiss briefing in this matter shall be: Defendants’ motion to dismiss: 25 pages Plaintiff’s opposition to Defendants’ motion to dismiss 25 pages 6 7 PURSUANT TO THE STIPULATION, IT IS SO ORDERED. 8 9 10 11 Dated: January 5 , 2012 __________________________________ The Honorable Jeffrey S. White United States District Judge 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4STIPULATION AND [PROPOSED] ORDER GRANTING LEAVE TO EXCEED PAGE LIMITS ESTABLISHED BY THE COURT’S CIVIL STANDING ORDERS

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