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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` 1 2 3 4 5 6 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: (650) 327-9800 Facsimile: (650) 618-1863 E-mail: Attorneys for Plaintiff INTEGRAL DEVELOPMENT CORPORATION 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 12 13 14 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. 15 VIRAL TOLAT, an individual, 16 Defendant. 17 18 19 20 21 22 23 24 25 26 27 28 Computerlaw Group LLP computerlaw.comsm JOINT STIPULATION CASE NO. 3:12-cv-06575-JSW ` Case3:12-cv-06575-JSW Document53 Filed04/01/13 Page2 of 3 1 JOINT STIPULATION 2 WHEREAS, on January 4, 2013, the Court issued an Order Setting Case Management 3 Conference and Requiring Joint Case Management Conference Statement (Dkt. 17), setting the Case 4 Management Conference for April 19, 2013, at 1:30 p.m. in Department 11; 5 WHEREAS, in the Court’s January 10, 2013, Order Denying [Integral’s] Ex Parte 6 Application for a Temporary Restraining Order (Dkt. 46), the Court permitted the parties certain 7 expedited discovery, specifically, that reciprocal document discovery be completed by no later than 8 January 31, 2013, depositions to be conducted by no later than February 14, 2013, and private 9 mediation to be completed by no later than March 14, 2013; 10 WHEREAS, in January, February and March of 2013, the parties exchanged document 11 discovery (over 50,000 pages) and conducted the depositions of eight (8) separate witnesses in 12 California and New York, including Defendant Viral Tolat and Harpal Sandhu (the Chief Executive 13 Officer of Plaintiff Integral Development Corporation); 14 WHEREAS, the parties are currently meeting and conferring and attempting to informally 15 resolve several discovery disputes, and plan to submit their disputes in Letter Briefs to Magistrate 16 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 17 18 19 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 20 21 22 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 23 scheduled mediation. 24 IT IS SO STIPULATED. 25 // 26 // 27 // 28 Computerlaw Group LLP computerlaw.comsm JOINT STIPULATION 1 CASE NO. 3:12-cv-06575-JSW ` 1 Case3:12-cv-06575-JSW Document53 Filed04/01/13 Page3 of 3 Dated: April 1, 2013 COMPUTERLAW GROUP LLP 2 By: 3 4 /s/ Jack Russo Jack Russo Attorneys for Plaintiff INTEGRAL DEVELOPMENT CORPORATION 5 6 Dated: April 1, 2013 KATTEN MUCHIN & ROSENMAN LLP 7 By: 8 9 /s/ Steven Eckhaus ____ Steven Eckhaus Attorneys for Defendant VIRAL TOLAT 10 ATTORNEY ATTESTATION 11 12 13 14 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: 15 16 /s/ Jack Russo Jack Russo Attorneys for Plaintiff INTEGRAL DEVELOPMENT CORPORATION 17 18 19 20 21 22 23 [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. 24 25 April 2, 2013 DATED: _________________ 26 27 _____________________________________ The Honorable Jeffrey S. White United States District Judge 28 Computerlaw Group LLP computerlaw.comsm JOINT STIPULATION 2 CASE NO. 3:12-cv-06575-JSW

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