Integral Development Corp v. Tolat
Filing
107
ORDER GRANTING AS MODIFIED 106 STIPULATION re: Revised Scheduling Order. Signed by Judge Jeffrey S. White on 7/18/13. (jjoS, COURT STAFF) (Filed on 7/18/2013)
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JACK RUSSO (State Bar No. 96068)
CHRISTOPHER SARGENT (State Bar No. 246285)
COMPUTERLAW GROUP LLP
401 Florence Street
Palo Alto, CA 94301
Telephone: (650) 327-9800
Facsimile: (650) 618-1863
E-mail: jrusso@computerlaw.com
csargent@computerlaw.com
Attorneys for Plaintiff
INTEGRAL DEVELOPMENT CORP.
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IN THE UNITED STATES DISTRICT COURT
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IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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INTEGRAL DEVELOPMENT CORP, a California Case No.: 3:12-cv-06575-JSW (LB)
corporation,
REVISED JOINT STIPULATION AND
[PROPOSED] SCHEDULING ORDER
Plaintiff,
v.
VIRAL TOLAT, an individual, and DOES 1-20,
Defendant.
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Computerlaw
Group LLP
computerlaw.com
Revised Stipulation and [Proposed] Order
Case No. 3:12-cv-06575-JSW
JOINT STIPULATION
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WHEREAS, Plaintiff Integral Development Corporation (“Integral”) and Defendant Viral Tolat
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(“Tolat”) engaged in a Settlement Conference on July 12, 2013 before Magistrate Judge Jacqueline
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Corley (Dkt. 105);
IT IS HEREBY STIPULATED that in the interests of judicial economy and in order to
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facilitate further settlement discussions, all stipulated and ordered filing deadlines, as enumerated
below, be continued until at least July 19, 2013;
IT IS HEREBY STIPULATED that the following deadlines as set by Stipulation and Order re:
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Schedule (Dkt 97) and by Joint Stipulation and [Proposed] Order to Re: Schedule (Dkt 104) are
amended to reflect this requested continuance:
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1. Plaintiff Integral shall file its First Amended Complaint on July 19, 2013;
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2. Defendant Tolat shall file his Answer and Counterclaims to Integral’s First Amended
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Complaint, and/or move with respect to some or all of the Amended Complaint on August
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9, 2013;
a. If Defendant files a Rule 12 Motion, Plaintiff’s Opposition shall be filed by August
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23, 2013; Defendant’s Reply shall be filed by August 30, 2013;
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3. Plaintiff Integral shall Answer Defendant Tolat’s Counterclaims and/or file any Opposition
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and/or responsive motions to such Counterclaims on August 30, 2013;
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a. If Plaintiff files a Rule 12 motion, Defendant’s Opposition shall be filed by
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September 13, 2013; Plaintiff’s Reply shall be filed by September 20, 2013;
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4. Any motions filed by Plaintiff Integral pertaining to Defendant Tolat’s Counterclaims, and
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any motions filed by Defendant Tolat concerning Plaintiff Integral’s Amended Complaint
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shall be heard on September 27, 2013, at 9:00 a.m.
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5. Plaintiff’s Motion for Sanctions Re: Spoliation and for Contempt
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a. Hearing Date: September 27, 2013 at 9:00 a.m.
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b. Plaintiff will file its moving papers by: July 19, 2013
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c. Defendant will file any opposition by: August 9, 2013
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d. Plaintiff will file any reply by: August 16, 2013.
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e. Each brief will be no longer than 15 pages
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Computerlaw
Group LLP
computerlaw.com
//
Revised Stipulation and [Proposed] Order
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Case No. 3:12-cv-06575- JSW
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6. Plaintiff’s Motions for Summary Adjudication and for Preliminary Injunction
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a. Hearing Date: September 27, 2013 at 9:00 a.m.
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b. Plaintiff will file its moving papers by: July 19, 2013
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c. Defendant will file any opposition by: August 9, 2013
d. Plaintiff will file any reply by: August 16, 2013.
e. Each brief will be no longer than 25 pages.
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7. Defendant’s Motions (i) to hold Integral in contempt for e.g. altering evidence and (ii) for
sanctions against Integral for e.g. intentionally misleading the Court
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a. Hearing Date: September 27, 2013 at 9:00 a.m.
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b. Plaintiff will file its moving papers by: August 19, 2013
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c. Defendant will file any opposition by: September 9, 2013
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d. Plaintiff will file any reply by: September 20, 2013.
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e. Each brief will be no longer than 15 pages
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8. Defendant’s Motions for Summary Judgment
a. Hearing Date: September 27, 2013 at 9:00 a.m.
b. Plaintiff will file its moving papers by: August 19, 2013
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c. Defendant will file any opposition by: September 9, 2013
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d. Plaintiff will file any reply by: September 20, 2013.
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e. Each brief will be no longer than 25 pages.
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IT IS SO STIPULATED
Dated: July 15, 2013
COMPUTERLAW GROUP LLP
By:
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/s/ Jack Russo
Jack Russo
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Attorneys for Plaintiff
INTEGRAL DEVELOPMENT CORP.
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Dated: July 15, 2013
KATTEN MUCHIN ROSENMAN LLP
By:
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/s/ Steven Eckhaus
Steven G. Eckhaus, pro hac vice
Stuart M. Richter
Attorneys for Defendant
VIRAL TOLAT
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Computerlaw
Group LLP
computerlaw.com
Revised Stipulation and [Proposed] Order
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Case No. 3:12-cv-06575- JSW
[PROPOSED] ORDER
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PURSUANT TO STIPULATION AND GOOD CAUSE SHOWN, the parties’ joint request is
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GRANTED, and the following schedule is hereby ORDERED:
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1. Plaintiff Integral shall file its First Amended Complaint on July 19, 2013;
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2. Defendant Tolat shall file his Answer and Counterclaims to Integral’s First Amended
Complaint on August 9, 2013;
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3. Plaintiff shall file its Answer and/or responsive motions to Defendant Tolat’s
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Counterclaims on August 30, 2013;
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4. Any motions filed by Plaintiff Integral pertaining to Defendant Tolat’s Counterclaims shall
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be heard on September 27, 2013, at 9:00 a.m.
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5. Plaintiff’s Motion for Sanctions Re: Spoliation and for Contempt
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a. Hearing Date: September 27, 2013 at 9:00 a.m.
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b. Plaintiff will file its moving papers by: July 19, 2013
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c. Defendant will file any opposition by: August 9, 2013
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d. Plaintiff will file any reply by: August 16, 2013.
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e. Each brief will be no longer than 15 pages
6. Plaintiff’s Motions for Summary Adjudication and for Preliminary Injunction
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a. Hearing Date: September 27, 2013 at 9:00 a.m.
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b. Plaintiff will file its moving papers by: July 19, 2013
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c. Defendant will file any opposition by: August 9, 2013
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d. Plaintiff will file any reply by: August 16, 2013.
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e. Each brief will be no longer than 35 pages.
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7. Defendant’s Motions (i) to hold Integral in contempt for e.g. altering evidence and (ii) for
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sanctions against Integral for e.g. intentionally misleading the Court
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a. Hearing Date: September 27, 2013 at 9:00 a.m.
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b. Plaintiff will file its moving papers by: August 19, 2013
September 3
c. Defendant will file any opposition by: September 9, 2013
September 10
d. Plaintiff will file any reply by: September 20, 2013.
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e. Each brief will be no longer than 15 pages
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//
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Computerlaw
Group LLP
computerlaw.com
Revised Stipulation and [Proposed] Order
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Case No. 3:12-cv-06575- JSW
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8. Defendant’s Motions for Summary Judgment
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a. Hearing Date: September 27, 2013 at 9:00 a.m.
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b. Plaintiff will file its moving papers by: August 19, 2013
September 3
c. Defendant will file any opposition by: September 9, 2013
September 10
d. Plaintiff will file any reply by: September 20, 2013.
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e. Each brief will be no longer than 25 pages.
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IT IS SO ORDERED.
Dated: July 18, 2013
_____
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___________ _____
The Honorable Jeffrey S. White
United States District Judge
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Computerlaw
Group LLP
computerlaw.com
Revised Stipulation and [Proposed] Order
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Case No. 3:12-cv-06575- JSW
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