Integral Development Corp v. Tolat

Filing 97

ORDER GRANTING AS MODIFIED 96 STIPULATION Re: Schedule. Motion Hearings set for 9/27/2013 09:00 AM in Courtroom 11, 19th Floor, San Francisco before Hon. Jeffrey S. White.. Signed by Judge Jeffrey S. White on 6/10/13. (jjoS, COURT STAFF) (Filed on 6/10/2013)

Case3:12-cv-06575-JSW Document96 Filed06/07/13 Page1 of 3

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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: [phone]
Facsimile: [phone]
E-mail: [e-mail]
[e-mail]
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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INTEGRAL DEVELOPMENT CORPORATION,
a California corporation,
Plaintiff,

Case No.: 3:12-cv-06575-JSW (LB)
STIPULATION AND [PROPOSED] ORDER RE:
SCHEDULE

vs.
VIRAL TOLAT, an individual,
Defendant.

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Computerlaw
Group LLP
computerlaw.com

Stipulation and [Prop.] Order re: Schedule

Case No. 3:12-cv-06575-JSW (LB)

Case3:12-cv-06575-JSW Document96 Filed06/07/13 Page2 of 3

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STIPULATION AND PROPOSED ORDER RE: SCHEDULE

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As ordered by the Court following the May 24, 2013 case management conference in this

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matter (Civ. Minute Order, Dkt. 90), the parties have conferred and stipulate to the following schedule,

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subject to the Court’s approval, regarding:
(1) Plaintiff’s motions:
(a) for sanctions re: spoliation of evidence and for finding of contempt, and

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(b) for summary adjudication and preliminary injunction.
(2) Defendant’s motions:

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(a) to hold Integral in contempt for e.g., altering evidence

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(b) for sanctions against Integral for e.g., intentionally misleading the Court, and

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(b) for Summary Judgment.
MOTIONS

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Parties further agree that in the interests of judicial economy, Plaintiff’s motions and
Defendant’s motions as described in above shall be made on the below schedule. Parties agree that
there shall be no waiver or prejudice to Plaintiff’s rights to the injunctive and other equitable and
requested relief sought by Plaintiff based on the proposed schedule.

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1. 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 16, 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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2. Plaintiff’s Motions for Summary Adjudication and for Preliminary Injunction
a. Hearing Date: September 27, 2013 at 9:00 a.m.
b. Plaintiff will file its moving papers by: July 16, 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.
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e. Each brief will be no longer than 35 pages.
3. Defendant’s Motions (i) to hold Integral in contempt for e.g., altering evidence and

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(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.

Computerlaw
Group LLP
computerlaw.com

Stipulation and [Prop.] Order re: Schedule

1

Case No. 3:12-cv-06575-JSW (LB)

Case3:12-cv-06575-JSW Document96 Filed06/07/13 Page3 of 3

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b. Defendant will file his Motions by: August 19, 2013.

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c. Plaintiff will file any Oppositions by: September 9, 2013.

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d. Defendant will file his Replies by September 20, 2013.
e. Each brief will be no longer than 15 pages.

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4. Defendant’s Motion for Summary Judgment

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a. Hearing Date: September 27, 2013 at 9:00 a.m.
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b. Defendant will file his Motion by: August 19, 2013.

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c. Plaintiff will file any Opposition by: September 9, 2013.

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d. Defendant will file his Reply by: September 20, 2013.
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e. Each brief will be no longer than 35 pages.

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Stipulated and respectfully submitted,

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Dated: June 7, 2013

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COMPUTERLAW GROUP LLP

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By:

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/s/ Jack Russo
Jack Russo, Attorney for Plaintiff

By:
/s/ Steven Eckhaus
Steven Eckhaus, pro hac vice

INTEGRAL DEVELOPMENT CORP.

Attorney for Defendant VIRAL TOLAT

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KATTEN MUCHIN ROSENMAN LLP

ATTORNEY ATTESTATION
As required by General Order 45, I attest that I have obtained concurrence in the filing of this

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document from the signatories indicated by the conformed signature (/s/) in this electronically filed

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document.
By: /s/ Jack Russo
Jack Russo

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Attorneys for Plaintiff
INTEGRAL DEVELOPMENT CORP

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[PROPOSED] ORDER

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____________

For good case shown, the above STIPULATION & PROPOSED ORDER RE: SCHEDULE is
approved and parties shall comply with its provisions.
IT IS SO ORDERED.
Dated: June 10, 2013
The Honorable Jeffrey S. White
UNITED STATES DISTRICT JUDGE

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Computerlaw
Group LLP
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Stipulation and [Prop.] Order re: Schedule

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Case No. 3:12-cv-06575-JSW (LB)