AutoOpt Networks, Inc. v. Karani et al

Filing 93

ORDER by Judge Haywood S. Gilliam, Jr. Granting 92 Stipulation for Extension of the Close of Fact Discovery Deadline for Completion of Certain Depositions. (ndrS, COURT STAFF) (Filed on 9/12/2018)

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Robert E. Camors, Jr. (CA Bar No. 121204)
[e-mail]
Law Offices Of Bob Camors
50 West San Fernando Street, Suite 1425
San Jose, California 95113
Telephone: [phone]
Facsimile: 408-573-5743
Chris Kao (CA Bar No. 227086)
[e-mail]
Andrew Hamill (CA Bar No. 251156)
[e-mail]
Whitney Miner (CA Bar No. 290825)
[e-mail]
KAO LLP
One Post Street, Suite 1000
San Francisco, California 94104
Telephone: [phone]
Facsimile: 866-267-0243
Attorneys for Defendant and Counter-Claimant
Gnanenthiran Jayanthan

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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AUTOOPT NETWORKS, INC., a California
corporation,

Case No. 4:17-cv-04714-HSG

Plaintiff,

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v.
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VIJAY KARANI, an individual; MOBILE
TERRACE, INC., a California corporation;
GNANENTHIRAN JAYANTHAN, an individual,

STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION THE
CLOSE OF FACT DISCOVERY
DEADLINE FOR COMPLETION OF
CERTAIN DEPOSITIONS
Hon. Haywood S. Gilliam, Jr.

Defendants.
WHEREAS, pursuant to this Court’s Schedule Order (Dkt. No. 34), the deadline for the
close of fact and expert discovery is September 14, 2018;
WHEREAS due to scheduling conflicts and the unavailability of witnesses and counsel,

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additional time is needed to take or complete certain depositions. They are the deposition of

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Defendant Gnanenthiran Jayanthan (“Jayanthan”), Plaintiff AutoOpt Networks, Inc. (“Autoopt”),

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STIPULATION AND [PROPOSED] ORDER

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and non-parties Dipesh Shah (Autoopt’s principal) and Dayalini Kanagaratnam, Defendant

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Jayanthan’s spouse;

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WHEREAS counsel for Jayanthan noticed the depositions of Mr. Shah and AutoOpt for

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August 28, 2018 but was unable to complete them on that date and the position of AutoOpt was

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that the depositions could not continue until September 12, 2018 and WHEREAS a dispute

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continues to exist between the Parties about whether or not the deposition of Mr. Shah or the

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deposition of AutoOpt has been commenced by Defendant which is not resolved by this

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stipulation;

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WHEREAS counsel for AutoOpt had noticed the deposition of both Defendant Mr.

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Jayanthan and Dayalini Kanagaratnam, Defendant Jayanthan’s spouse, for September 12, 2018

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pursuant to agreement which is the same date proposed by AutoOpt for continuation of the Mr.

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Shah and/or AutoOpt depositions.

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WHEREAS the counsel for Defendant Mr. Jayanthan and counsel for Plaintiff AutoOpt

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have met and conferred concerning the problem arising because of the timing issues described

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above and agree that they cannot reasonably complete these depositions on September 12, 2018

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or before the court-ordered discovery cutoff date of September 14, 2018, due to the above-

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mentioned depositions being set on the same date and also due to a Califoria Superior Court trial

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start date that is set for Defendant Jayanthan’s counsel on September 14, 2018 and related

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pretrial actions needed on September 13, 2018;

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WHEREAS counsel for AutoOpt has California Superior Court trial start date set on

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September 24, 2018 which prevents these depositions from continuing until completion of that

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trial estimated to last to mid-to late October 2018;

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WHEREAS meet and confer has occurred between the undersigned counsel for the
parties who have stipulated and agree to the following way to resolve the above situation:
NOW THEREFORE, IT IS HEREBY STIPULATED by and between the parties,
through their respective attorneys of record, that in the interest of justice, the deadline for

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STIPULATION AND [PROPOSED] ORDER

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completion of the depositions named above is extended to and including Friday, November 16,

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2018.

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No other court Deadline is changed by this STIPULATION which remain in effect as
stated in the below table:

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Event

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Close of Fact and Expert Discovery except as

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specified in this Order

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Dispositive Motion Hearing Deadline

November 15, 2018

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Pretrial Conference

February 5, 2019 at 8:30 a.m.

5-Day Jury Trial

February 25, 2019 at 8:30 a.m.

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Current Court Deadline
September 14, 2018

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The Parties agree that good cause exists for this extension because:

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1. The parties believe that they will suffer prejudice if they are not permitted to complete the

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depositions of the foregoing individuals and entity; and
2. No other deadlines will be affected by this stipulation.
Dated: September 11, 2018
By: _/s/ Robert E. Camors, Jr. ___________
Robert E. Camors, Jr. (CA Bar No. 121204)
[e-mail]
Law Offices Of Bob Camors

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Chris Kao (CA Bar No. 227086)
[e-mail]
Andrew Hamill (CA Bar No. 251156)
[e-mail]
Whitney Miner (CA Bar No. 290825)
[e-mail]
KAO LLP

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Attorneys for Defendant and CounterClaimant Gnanenthiran Jayanthan

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STIPULATION AND [PROPOSED] ORDER

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Dated: September 11, 2018

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By: /s/ Paul J. Steiner
Paul J. Steiner (CA Bar No. 41117)
[e-mail]

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Attorney for Plaintiff AutoOpt Networks, Inc.

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[PROPOSED] ORDER

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Pursuant to the parties’ stipulation, and good cause appearing therefor, it is hereby

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ORDERED that the deadline for completion of the depositions named above is extended to and

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includes Friday, November 16, 2018. Except for those depositions, the Close of Fact Discovery

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remains September 14, 2018.

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This modification does not change any other existing scheduling deadline, including the
pre-trial conference and trial dates.
IT IS SO ORDERED.
Dated: September ___, 2018
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____________________
Hon. Haywood S. Gilliam, Jr.
United States District Judge

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STIPULATION AND [PROPOSED] ORDER