Jackson v. Fischer et al
Filing
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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)
Case3:11-cv-02753-JSW Document59 Filed01/04/12 Page1 of 5
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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
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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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SUZANNE D. JACKSON,
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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.
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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
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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:
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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.
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Dated: January 4, 2012
KAUFMAN LLC
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By: /s/ Alan H. Kaufman
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Alan H. Kaufman
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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
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Dated: January 4, 2012
THE LAW OFFICES OF TOM CHIA-KAI WANG
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By: /s/ Tom Chia Kai Wang
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Tom Chia Kai Wang
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Attorneys for Defendants Chetan Narsude, Mani
Kulasooriya, Monvia LLC and New Moon LLC
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-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
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[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
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PURSUANT TO THE STIPULATION, IT IS SO ORDERED.
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Dated: January 5 , 2012
__________________________________
The Honorable Jeffrey S. White
United States District Judge
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-4STIPULATION AND [PROPOSED] ORDER GRANTING LEAVE TO EXCEED PAGE LIMITS
ESTABLISHED BY THE COURT’S CIVIL STANDING ORDERS
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