Integral Development Corp v. Tolat

Filing 54

ORDER GRANTING 53 STIPULATION to Continue Case Management Conference. Case Management Statement due by 6/7/2013. Case Management Conference set for 6/14/2013 01:30 PM in Courtroom 11, 19th Floor, San Francisco.. Signed by Judge Jeffrey S. White on 4/2/13. (jjoS, COURT STAFF) (Filed on 4/2/2013)

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Case3:12-cv-06575-JSW Document53 Filed04/01/13 Page1 of 3

JACK RUSSO (State Bar No. 96068)
CHRISTOPHER SARGENT (State Bar No. 246285)
COMPUTERLAW GROUP LLP
401 Florence Street
Palo Alto, CA 94301
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
[e-mail]
Attorneys for Plaintiff
INTEGRAL DEVELOPMENT CORPORATION

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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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INTEGRAL DEVELOPMENT CORPORATION, Case No. 3:12-cv-06575-JSW
a California corporation,
JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CASE
Plaintiff,
MANAGEMENT CONFERENCE
v.

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VIRAL TOLAT, an individual,
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Defendant.
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JOINT STIPULATION

CASE NO. 3:12-cv-06575-JSW

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Case3:12-cv-06575-JSW Document53 Filed04/01/13 Page2 of 3

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JOINT STIPULATION

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WHEREAS, on January 4, 2013, the Court issued an Order Setting Case Management

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Conference and Requiring Joint Case Management Conference Statement (Dkt. 17), setting the Case

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Management Conference for April 19, 2013, at 1:30 p.m. in Department 11;

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WHEREAS, in the Court’s January 10, 2013, Order Denying [Integral’s] Ex Parte

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Application for a Temporary Restraining Order (Dkt. 46), the Court permitted the parties certain

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expedited discovery, specifically, that reciprocal document discovery be completed by no later than

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January 31, 2013, depositions to be conducted by no later than February 14, 2013, and private

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mediation to be completed by no later than March 14, 2013;

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WHEREAS, in January, February and March of 2013, the parties exchanged document

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discovery (over 50,000 pages) and conducted the depositions of eight (8) separate witnesses in

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California and New York, including Defendant Viral Tolat and Harpal Sandhu (the Chief Executive

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Officer of Plaintiff Integral Development Corporation);

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WHEREAS, the parties are currently meeting and conferring and attempting to informally

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resolve several discovery disputes, and plan to submit their disputes in Letter Briefs to Magistrate

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Judge Laurel Beeler in the event that the parties are unable to resolve their differences;
WHEREAS, the parties are in the process of scheduling mediation, anticipated to occur in

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May of this year and with the goal of the Case Management Conference in June 2013 if the case is
not resolved in mediation;
IT IS HEREBY STIPULATED and agreed that, in order to ensure that the Case Management

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Conference is as efficacious as possible, the parties jointly request that the Court continue the Case
Management Conference so that it occurs after the parties’ mediation; specifically, the parties request
permission to file the Joint Case Management Conference Statement in June 2013 following the

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scheduled mediation.
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IT IS SO STIPULATED.
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//
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Computerlaw
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computerlaw.comsm

JOINT STIPULATION

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CASE NO. 3:12-cv-06575-JSW

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Case3:12-cv-06575-JSW Document53 Filed04/01/13 Page3 of 3

Dated: April 1, 2013

COMPUTERLAW GROUP LLP

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By:

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/s/ Jack Russo
Jack Russo
Attorneys for Plaintiff
INTEGRAL DEVELOPMENT
CORPORATION

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Dated: April 1, 2013

KATTEN MUCHIN & ROSENMAN LLP

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By:

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/s/ Steven Eckhaus ____
Steven Eckhaus
Attorneys for Defendant
VIRAL TOLAT

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ATTORNEY ATTESTATION

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Pursuant to General Order 45, I hereby attest that concurrence in the filing of this
document has been obtained from the signatories indicated by a ‘conformed’ signature (/s/) within
this e-filed document.
By:

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/s/ Jack Russo
Jack Russo
Attorneys for Plaintiff
INTEGRAL DEVELOPMENT
CORPORATION

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[PROPOSED] ORDER
PURSUANT TO STIPULATION AND GOOD CAUSE SHOWN, the parties’ joint request is
GRANTED and the Case Management Conference is continued and shall be held on
___________________, 2013, with the Joint Case Management Conference Statement to be filed by
June 14
June 7
___________________, 2013.
IT IS SO ORDERED.

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April 2, 2013
DATED: _________________

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_____________________________________
The Honorable Jeffrey S. White
United States District Judge

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Computerlaw
Group LLP
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JOINT STIPULATION

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CASE NO. 3:12-cv-06575-JSW