Maktab Tarighe, et al v. Kianfar, et al

Filing 168

STIPULATION AND ORDER GRANTING REQUEST TO EXTEND THE NON-EXPERT DISCOVERY DEADLINE re 167 Letter filed by MTO Shahmaghsoudi (School of Islamic Sufism) Global, Inc., Maktab Tarighat Oveyssi Shahmaghsoudi. Signed by Judge Phyllis J. Hamilton on 11/9/15. (jebS, COURT STAFF) (Filed on 11/9/2015)

BARNES & THORNBURG LLP
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Joseph D. Lewis

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VIA ECF

November 6, 2015
Chief District Judge Phyllis J. Hamilton
United States District Court
Northern District of California
Oakland Courthouse, Courtroom 3 - 3rd Floor
1301 Clay Street, Oakland, CA 94612
Re:

Maktab Tarighe, et al v. Ali Kianfar, et al
U.S.D.C. for the Northern District of California
Case No.:
4:95-cv-02881-PJH
Our File:
718-35347-3

Your Honor:
Under the Court’s Order dated August 12, 2015 (Docket No. 158), the non-expert discovery
cutoff in the captioned matter is November 30, 2015. Pursuant to Local Rules 7-11 and 7-12, the
parties hereby jointly request that this deadline be extended fifteen (15) days, to and including
December 15, 2015.
Good cause supports this joint request. First, the extension will grant the parties the
opportunity to advance a recent and productive line of settlement discussions without the burden of
completing non-expert discovery simultaneously. The parties for many years have been unable to
agree as to what they can and cannot do with regard to possible future actions about the trademarks
at issue. Through the work of counsel, including personal counsel for the defendants, they have
come to terms on this set of issues. The only remaining issue is financial, and that is in the hands of
the defendants’ carrier. Second, the extension will not affect the overall case schedule delineated in
the Court’s December 9, 2014 Case Management Order (Docket No. 133). Pursuant to that Order,
expert disclosures are not due until January 15, 2016, a month after the new non-expert cutoff
proposed here. Third, this 15-day extension is narrowly tailored to meet the needs of the parties and
to address any scheduling difficulties created by the approaching Thanksgiving holiday.
Atlanta

Chicago

Dallas

Delaware

Indiana

Los Angeles

Michigan

Minneapolis

Ohio

Washington, D.C.

Chief District Judge Phyllis J. Hamilton
November 6, 2015

For the foregoing reasons, the parties respectfully jointly request a fifteen (15) day extension
of the non-expert discovery cutoff to and including December 15, 2015.
Respectfully submitted,
BARNES & THORNBURG
JOSEPH D. LEWIS

By:

/s/
Joseph D. Lewis

Counsel for Plaintiffs
MAKTAB TARIGHE
OVEYSSI MAGHSOUDI, INC.
AND NADER ANGHA

DILLINGHAM & MURPHY, LLP
JOHN N. DAHLBERG
By:

/s/
John N. Dahlberg

Counsel for Defendants
ALI KIANFAR, NAHID KIANFAR, AND
INTERNATIONAL ASSOCIATION OF SUFISM

I, Joseph D. Lewis, am the ECF User whose identification and password are being used to
file this document. Pursuant to Civil Local Rule 5.1, I hereby attest that counsel for defendants has
concurred in this filing.
/s/
Joseph D. Lewis

The parties’ request to extend the non-expert discovery cutoff from November 30, 2015 to
December 15, 2015 is GRANTED.

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The Honorable PhyllislisJ. Hamilton
Hamilton
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Judge P
United States District Judge
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Dated: November 9, 2015

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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