Jackson v. Fischer et al

Filing 81

ORDER GRANTING 80 STIPULATION to Extend Time to Respond to Motions to Dismiss and to Reply. Signed by Judge Jeffrey S. White on 2/22/12. (jjoS, COURT STAFF) (Filed on 2/22/2012)

Case3:11-cv-02753-JSW Document80 Filed02/21/12 Page1 of 6

1 KAUFMAN LLC

ALAN H. KAUFMAN
2 445 Park Avenue
New York, New York 10022
3 Telephone: [phone]
Facsimile:
646-820-6568
Appearing Pro Hac Vice
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5 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
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A Limited Liability Partnership
Including Professional Corporations
ROBERT J. STUMPF, JR., Cal. Bar No. 72851
[e-mail]
Four Embarcadero Center, 17th Floor
San Francisco, California 94111-4109
Telephone:
415-434-9100
Facsimile:
415-434-3947

10 Attorneys for Plaintiff Suzanne D. Jackson
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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15 SUZANNE D. JACKSON,
Plaintiff,

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v.

18 WILLIAM FISCHER, JON SABES, STEVEN
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Case No. CV 11-2753 JSW

SABES, DAVID GOLDSTEEN, MARVIN
SIEGEL, BRIAN CAMPION, LONNIE
BOOKBINDER, 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,

STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME TO
RESPOND TO MOTIONS TO DISMISS
AND TO REPLY; DECLARATION OF
ROBERT J. STUMPF IN SUPPORT
THEREOF

Defendant.

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W02-WEST:5DAS1\404661642.2

STIP AND PROPOSED ORDER TO EXTEND TIME TO
RESPOND TO MOTIONS

Case3:11-cv-02753-JSW Document80 Filed02/21/12 Page2 of 6

STIPULATION

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Pursuant to Federal Rule of Civil Procedure Civil L.R. 6-1(b), 6-2, and 7-12, it is hereby

3 stipulated by and between the parties, through their respective attorneys, that:
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WHEREAS, Plaintiff Suzanne Jackson ("Jackson") filed and served her First Amended

5 Complaint on December 5, 2011;
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WHEREAS, Jackson and Defendants William Fischer, Upper Orbit LLC, Jon Sabes,

7 Steven Sabes, Marvin Siegel, Mani Koolasuriya, Monvia LLC, Chetan Narsude and New Moon
8 LLC ("Defendants") previously stipulated that Defendants’ last day to answer or otherwise
9 respond to the First Amended Complaint would be January 13, 2012;
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WHEREAS, Defendants requested an additional extension of time to answer or otherwise

11 respond to the First Amended;
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WHEREAS, Plaintiff agreed to extend Defendants’ time to answer or

13 otherwise respond to the First Amended Complaint to January 27, 2012;
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WHEREAS, Defendants agreed that Plaintiff’s opposition to the motions to

15 dismiss would be due on or before February 24, 2012;
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WHEREAS, Jackson requested an additional extension of time to oppose the motions to

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dismiss, to March 16, 2012;
WHEREAS, Defendants agreed that Plaintiff’s opposition to the motions to dismiss would
be due on or before March 16, 2012;
WHEREAS the parties further agreed that Defendants would have an extension of time to
file replies on their motions to dismiss, such that they would be due on or before April 9, 2012;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED THAT, subject to
the Court’s approval, Plaintiff shall file and serve her opposition to Defendants’ motions to
dismiss on or before March 16, 2012, and Defendants shall file and serve their reply papers on or
before April 9, 2012.

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STIP AND PROPOSED ORDER TO EXTEND TIME TO
RESPOND TO MOTIONS

Case3:11-cv-02753-JSW Document80 Filed02/21/12 Page3 of 6

1 Dated: February 21, 2012
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Dated: February 21, 2012

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Dated: February 21, 2012

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Dated: February 21, 2012

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/s/ Robert J. Stumpf, Jr.
Robert J. Stumpf, Jr.
SHEPPARD MULLIN RICHTER & HAMPTON LLP
Attorneys for Plaintiff Suzanne Jackson
/s/ Peter C. McMahon
Peter C. McMahon
MCMAHON SEREPCA LLP
Attorneys for Defendants William Fischer and Upper
Orbit, LLC
/s/ Tanya Herrera
Tanya Herrera
STEIN & LUBIN LLP
Attorneys for Defendants Jon Sabes, Steven Sabes,
and Marvin Siegel
/s/ Tom Chia-Kai Wang
Tom Chia-Kai Wang
LAW OFFICES OF TOM CHIA-KAI WANG
Attorneys for Defendants Chetan Narsude, Mani
Kulasooriya, Monvia LLC, and New Moon LLC

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Filer's Attestation: Pursuant to General Order No. 45, Section X(B) regarding signatures, Robert
14 J. Stumpf, Jr. hereby attests that concurrence in the filing of this document has been obtained.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
February 22
Dated: _______________, 2012

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_______________________________
The Hon. Jeffrey S. White

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W02-WEST:5DAS1\404661642.2

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STIP AND PROPOSED ORDER TO EXTEND TIME TO
RESPOND TO MOTIONS