Jackson v. Fischer et al

Filing 79

ORDER GRANTING 61 Stipulation for Leave to Exceed Page Limits Established by the Court's Civil Standing Orders. Signed by Judge Jeffrey S. White on 1/30/12. (jjoS, COURT STAFF) (Filed on 1/30/2012)

Case3:11-cv-02753-JSW Document61 Filed01/06/12 Page1 of 4

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Theodore A. Griffinger, Jr. (SBN 66028)
Tanya Herrera (SBN 177790)
STEIN & LUBIN LLP
Transamerica Pyramid
600 Montgomery Street, 14th Floor
San Francisco, CA 94111
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]

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Attorneys for Defendants,
JON SABES, STEVEN SABES AND MARVIN
SIEGEL

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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,
Plaintiff,

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v.

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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

WILLIAM FISCHER; JON SABES;
STEVEN SABES; DAVID GOLDSTEEN;
MARVIN SIEGEL; BRIAN CAMPION;
LONNIE BROOKBINDER; CHETAN
NARSUDE; MANI KOOLASURIYA;
JOSHUA ROSEN; UPPER ORBIT, LLC;
SPECIGEN, INC.; PEER DREAMS INC.;
NOTEBOOKZ INC.; ILEONARDO.COM
INC.; NEW MOON LLC; MONVIA LLC;
and SAZANI BEACH HOTEL,

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Defendants.
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Plaintiff Suzanne Jackson and Defendants Jon Sabes, Steven Sabes and Marvin

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Siegel (collectively "Defendants"), by and through their counsel, and subject to the Court's

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approval, stipulate as follows:
WHEREAS, Plaintiff filed a First Amended Complaint ("FAC") on December 5,

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2011;
WHEREAS, the FAC asserts purported federal securities fraud and common law

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Case No. 3:11-cv-02753-JSC
STIPULATION AND [PROPOSED] ORDER GRANTING LEAVE TO EXCEED PAGE LIMITS
ESTABLISHED BY THE COURT’S CIVIL STANDING ORDERS

68530002/452509v1

Case3:11-cv-02753-JSW Document61 Filed01/06/12 Page2 of 4

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claims related to Plaintiffs’ investments;

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WHEREAS, the FAC alleges, inter alia, that Defendants engaged in a

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comprehensive scheme to defraud Plaintiff in violation of the Securities Exchange Act of 1934

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and the Securities Act of 1933 and by failing to provide and failing to disclose material facts,

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which purportedly constitute common law fraud;

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WHEREAS, the parties agree that the FAC's scope and complexity warrant a

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modest increase in the page limits imposed by this Court's Civil Standing Orders for Defendants'

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opening brief and Plaintiff's opposition brief to Defendants' motion to dismiss, but that the page

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limit for Defendants' reply brief shall remain 15 pages;

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NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED BY
AND BETWEEN THE PARTIES, subject to the Court's approval, that:

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1.

Defendants' memorandum of law in support of their motion to dismiss shall

not exceed 25 pages; and

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2.

Plaintiffs memorandum of law in opposition to Defendants' motion to

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dismiss shall not exceed 25 pages.

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Dated: January 6, 2011

KAUFMAN LLC

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By: /s/ Alan H. Kaufman
Alan H. Kaufman
Attorneys for Plaintiff Suzanne D. Jackson

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Dated: January 6, 2011

STEIN & LUBIN LLP

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By: /s/ Tanya Herrera
Tanya Herrera
Attorneys for Defendants
Jon Sabes, Steven Sabes and Marvin Siegel

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Case No. 3:11-cv-02753-JSC
STIPULATION AND [PROPOSED] ORDER GRANTING LEAVE TO EXCEED PAGE LIMITS
ESTABLISHED BY THE COURT’S CIVIL STANDING ORDERS

68530002/452509v1

Case3:11-cv-02753-JSW Document61 Filed01/06/12 Page3 of 4

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[PROPOSED] ORDER
Having reviewed the above stipulation, IT IS HEREBY ORDERED that the page

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limits for the motion to dismiss briefing in this matter shall be:

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Defendants’ motion to dismiss:

25 pages

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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 _____, 2012

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________________________________
The Honorable Jeffrey S. White
United States District Judge

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By: CHIEF JUDGE JAMES WARE

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Case No. 3:11-cv-02753-JSC
STIPULATION AND [PROPOSED] ORDER GRANTING LEAVE TO EXCEED PAGE LIMITS
ESTABLISHED BY THE COURT’S CIVIL STANDING ORDERS

68530002/452509v1