Farhang v. Indian institute of Technology Kharagpur et al

Filing 412

STIPULATION AND ORDER 408 Continuing Filing Deadlines and Hearing. Set/Reset Deadlines as to 403 MOTION to Dismiss Pursuant to the Foreign Sovereign Immunities Act and Motion to Vacate Prior Immunity Ruling. Motion Hearing set for 9/20/2013 09:00 AM in Courtroom 6, 4th Floor, San Jose before Hon. Ronald M. Whyte. Signed by Judge Ronald M. Whyte on 7/24/13. (jg, COURT STAFF) (Filed on 7/24/2013)

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SANJIV N. SINGH (SBN 193525)
[e-mail]
SANJIV N. SINGH, A PROFESSIONAL LAW CORPORATION
21 Columbus Avenue, Suite 205
San Francisco CA, 94122
Telephone: [phone]
Facsimile: 415-358-4006

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MICAH R. JACOBS (SBN 174630)
[e-mail]
JACOBS LAW GROUP SF
388 Market St., Suite 1300
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415-445-4697

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Attorneys for Plaintiffs
MANDANA D. FARHANG and M.A. MOBILE LTD.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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M.A. MOBILE LTD., a limited liability
company chartered in Dominica; and
MANDANA D. FARHANG,

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Plaintiffs,

CASE NO. C-08-02658-RMW (HRL)
JOINT STIPULATION AND
[] ORDER CONTINUING
FILING DEADLINES AND HEARING
DATE

v.
INDIAN INSTITUTE OF TECHNOLOGY
KHARAGPUR, an Indian Institute of
Technology incorporated under the
“Institutes of Technology Act, 1961”;
PARTHA P. CHAKRABARTI; and DOES 1
through 100, inclusive,

Date:
Time:
Dept:
Judge:

August 16th, 2013
9:00 a.m.
Courtroom 6, 4th Floor
Hon. Ronald M. Whyte

Defendants.

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C:\Users\thz\Desktop\2013-7-15 [PD] ORDERExtending
JOINT STIPULATION AND Stipulation CONTINUING FILING DEADLINES AND HEARING D ATE
Time.doc

CASE NO. C-08-02658 RMW (HRL)

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Plaintiffs Mandana D. Farhang and M.A. Mobile Ltd. (“Plaintiffs”), and Defendants

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Indian Institute of Technology, Kharagpur and Partha P. Chakrabarti (collectively “Defendants”)

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through their undersigned counsel, hereby submit this stipulation to continue the hearing on

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Defendant IIT’s Motion to Dismiss Pursuant To The Foreign Sovereign Immunities Act and

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Motion to Vacate Prior Immunity Ruling filed by Defendant IIT, from August 16, 2013 at 9:00

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a.m. to September 20, 2013 at 9:00 a.m.

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WHEREAS, Plaintiffs’ counsel just learned of the July 11, 2013 mandate transferring

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jurisdiction back to this Court and had planned their work calendars for August prior to that date;

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WHEREAS, Defendants noticed and filed their motion and hearing date on July 11,

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2013, after the mandate was issued and Plaintiffs thus have substantial, previously scheduled

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professional commitments scheduled for all available hearing dates in August which conflict

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directly with the original briefing and hearing schedule set for August 16, 2013;

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WHEREAS, besides brief continuances requested by both parties when IIT first entered

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the case in 2009 and during the brief period in 2009 when Ms. Farhang was acting pro per, there

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have been relatively few requests for changes in hearing dates or briefing schedules and all such

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requests have been for modest periods of time (see e.g. Dkt. Nos. 78, 271, 298, 314 and 347);

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WHEREAS, Plaintiffs have conferred with Defendants’ counsel, suggested several dates

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and choices, and Defendants have promptly agreed to a briefing schedule and hearing schedule

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which accommodates these conflicts and will not materially delay the disposition of the case

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before the Court;

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THEREFORE, IT IS HEREBY STIPULATED that:

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1.

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Plaintiffs’ Opposition to the Motions and all supporting documentation may be

filed on or before August 12, 2013;

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2.

Defendants’ Reply to the Motions may be filed on or before September 6, 2013;

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3.

The hearing set for August 16, 2013, at 9:00 a.m., may be continued to September

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20, 2013 at 9:00 a.m., or such other later date and time as the Court may set.

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JOINT STIPULATION AND [] ORDER CONTINUING FILING DEADLINES AND HEARING D ATE

CASE NO. C-08-02658 RMW (HRL)

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IT IS SO STIPULATED.

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Dated: July 16, 2013

SANJIV N.SINGH, A PROFESSIONAL LAW
CORP.

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/s/ Sanjiv N. Singh
Sanjiv N. Singh
Attorneys for Plaintiffs
MANDANA D. FARHANG and
M.A. MOBILE LTD.

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DATE: July 16, 2013

ORRICK, HERRINGTON & SUTCLIFFE LLP

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/s/ Benjamin Lin
Benjamin Lin
Attorneys for Defendants
INDIAN INSTITUTE OF TECNOLOGY,
KHARAGPUR and PARTHA CHAKRABARTI

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JOINT STIPULATION AND [] ORDER CONTINUING FILING DEADLINES AND HEARING D ATE

CASE NO. C-08-02658 RMW (HRL)

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ORDER

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GOOD CAUSE HAVING BEEN SHOWN, the hearing date for Defendant IIT’s

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Motion to Dismiss Pursuant To The Foreign Sovereign Immunities Act and Motion to Vacate

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Prior Immunity Ruling filed by Defendant IIT, shall be moved from August 16, 2013 at 9:00

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a.m. to September 20, 2013 at 9:00 a.m. Plaintiffs’ Opposition to the Motions shall be filed no

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later than August 12, 2013 and Defendants’ Reply to the Motions shall be filed no later than

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September 6, 2013.

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IT IS SO ORDERED.

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DATED: ______________
Honorable Ronald M. Whyte
United States District Judge
Northern District of California

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JOINT STIPULATION AND [] ORDER CONTINUING FILING DEADLINES AND HEARING D ATE

CASE NO. C-08-02658 RMW (HRL)