In Re Application of Ilyas Khrapunov

Filing 21

STIPULATION AND ORDER GRANTING EXTENSION FOR REPLY re 20 . STIPULATION WITH PROPOSED ORDER Granting Extension of Time for Reply Papers filed by John Doe, Ilyas Khrapunov, Pavel Prosyankin. Signed by Magistrate Judge Kandis A. Westmore on 10/20/17. (sisS, COURT STAFF) (Filed on 10/20/2017)

1 JEFFREY L. BORNSTEIN – 099358
MICHAEL FREEDMAN – 262850
2 CARA E. TRAPANI – 313411
ROSEN BIEN GALVAN & GRUNFELD LLP
3 50 Fremont Street, 19th Floor
San Francisco, California 94105-2235
4 Telephone: [phone]
Facsimile: [phone]
[e-mail]
5 Email:
[e-mail]
[e-mail]
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7 ATTORNEYS FOR NON-PARTIES
PAVEL PROSYANKIN AND JOHN DOE
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION

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13 IN RE APPLICATION OF ILYAS
KHRAPUNOV PURSUANT TO 28
14 U.S.C. § 1782 FOR THE TAKING OF
DISCOVERY FOR USE IN A FOREIGN
15 PROCEEDING

Case No. 4:17-mc-80107-KAW

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Judge: Hon. Kandis A. Westmore
Date: November 16, 2017
Time: 1:00 p.m.

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STIPULATION AND [PROPOSED]
ORDER GRANTING EXTENSION OF
TIME FOR REPLY PAPERS

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[3186490.1]

Case No. 17-mc-80107-KAW
STIPULATION AND [PROPOSED] ORDER GRANTING EXTENSION OF TIME FOR REPLY PAPERS

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Petitioner filed its opposition to the Motion to Quash the Subpoena on October 16,

2 2017. Non-Parties’ reply papers are due on October 23, 2017. Undersigned counsel
3 requests a two-day extension of time, to and including October 25, 2017 to file reply
4 papers because he will be out of the state from October 19-23, 2017. Petitioner’s counsel
5 has no objections to this request so long as the Court will maintain the hearing date of
6 November 16, 2017.
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It is respectfully requested that the Court grant this request for extension of time.

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DATED: October 18,2017

Respectfully submitted,

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ROSEN BIEN GALVAN & GRUNFELD LLP

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By:

/s/ Jeffrey L. Bornstein
Jeffrey L. Bornstein

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Attorneys for Non-Parties
Pavel Prosyankin and John Doe

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By:

/s/ Martha Boersch
Martha Boersch

Attorneys for Applicant
Ilyas Khrapunov

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CIVIL LOCAL RULE 5-1(i)(3)
Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this

24 document has been obtained from each of the signatories hereto.
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/s/ Jeffrey L. Bornstein
Jeffrey L. Bornstein

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[3186490.1]

Case No. 17-mc-80107-KAW
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STIPULATION AND [PROPOSED] ORDER GRANTING EXTENSION OF TIME FOR REPLY PAPERS

[PROPOSED] ORDER

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Based upon the representations of counsel and for good cause shown, IT IS

3 HEREBY ORDERED that Non-Parties’ request for a two-day extension of time to file
4 its’ reply papers is granted and the reply is now due on October 25, 2017. The hearing will
5 remain as scheduled for November 16, 2017.
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20,
7 DATED: October __ 2017

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____________________________________
THE HONORABLE KANDIS A. WESTMORE
United States Magistrate-Judge

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[3186490.1]

Case No. 17-mc-80107-KAW
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STIPULATION AND [PROPOSED] ORDER GRANTING EXTENSION OF TIME FOR REPLY PAPERS