Pravin et al v. Wipro, Inc.

Filing 132

STIPULATION AND ORDER RE 131 TO MODIFY CASE MANAGEMENT SCHEDULING ORDER. Further Case Management Conference set for 11/17/2011 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 9/1/11. (cl, COURT STAFF) (Filed on 9/1/2011)

*E-Filed 9/1/11*
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MICHAEL J. IOANNOU (SBN 95208)
DANIEL P. McKINNON (SBN 234749)
ROPERS, MAJESKI, KOHN & BENTLEY
50 West San Fernando Street, Suite 1400
San Jose, CA 95113-2429
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail];
[e-mail]
Attorneys for Defendant
WIPRO, INC., a Delaware Corporation

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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A Professional Corporation
San Jose

Ropers Majeski Kohn & Bentley

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PRAVIN JAIN, RANDY HOLTHAUS,
DILIP KUKREJA, MARK WARNER, and
DOUGLAS TANNER,

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Plaintiffs,

CASE NO. 5:09-cv-02743-RS
STIPULATION TO MODIFY CASE
MANAGEMENT SCHEDULING ORDER;
[PROPOSED] ORDER

v.
WIPRO, INC., a Delaware corporation,

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Defendants.

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IT IS HEREBY STIPULATED, by and between Plaintiffs PRAVIN JAIN, RANDY

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HOLTHAUS, DILIP KUKREJA, MARK WARNER, and DOUGLAS TANNER (collectively

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“Plaintiffs”) and Defendant WIPRO, INC. (“Wipro” or “Defendant”), through their respective

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counsel of record, and pursuant to Civil Local Rule 6-2, that the Case Management Scheduling

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Order filed on June 30, 2011 (“Scheduling Order”)(Doc. 125), be modified to allow expert

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depositions, non-party witness Ashwin Kedia’s (“Kedia”) deposition, and the deposition of

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Deepak Chandran (“Chandran”), to be taken on or before November 15, 2011. The parties

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further request that the Case Management Conference currently set for September 15, 2011, be

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vacated and reset to November 17, 2011, following the completion of these depositions.

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Pursuant to the Scheduling Order and Order Re: Discovery filed on August 19, 2011
RC1/6132725.2/DPM

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CASE NO. 5:09-cv-02743-RS

Stipulation to Modify Case Management Scheduling Order; [Proposed] Order

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(Doc. 129), expert and non-expert discovery was to be completed on or before September 15,

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2011. The parties are working together to schedule the depositions of their experts. In order to

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accommodate the availability of the experts and counsel, the parties agree to extend the time to

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complete expert depositions to September 15, 2011.

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The deposition of non-party witness Kedia is currently scheduled for September 6, 2011,

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pursuant to a properly served subpoena. The parties stipulate as set forth herein because Kedia

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has recently informed counsel for Wipro that he is currently in India attending to his sick mother

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and was still to be in India on September 6, 2011. Kedia further stated that his early departure

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from India and return to the United States would cause discomfort for him and his family. The
modification to the Scheduling Order will permit Kedia to avoid the expense and other hardships

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A Professional Corporation
San Jose

Ropers Majeski Kohn & Bentley

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of returning to the United States for deposition on September 6, 2011.

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Chandran is a PMK witness for Wipro and resides in India. His deposition was taken in

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India, but was not completed. Chandran is currently in Singapore and the parties are working

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together to schedule his further deposition here in the United States.

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Trial in this matter is not scheduled to commence until September 10, 2012. See Doc. No.

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125. Allowing the depositions of the experts, Kedia, and Chandran to be completed on or before

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November 15, 2011, will not prejudice the parties, or impose any burden on the Court.

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Further, the parties request that the Case Management Conference currently scheduled for

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September 15, 2011, be vacated and reset to November 17, 2011, following the completion of

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these depositions.

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RC1/6132725.2/DPM

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CASE NO. 5:09-cv-02743-RS

Stipulation to Modify Case Management Scheduling Order; [Proposed] Order

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IT IS SO STIPULATED:
Dated: September 1, 2011

ROPERS, MAJESKI, KOHN & BENTLEY

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By: /s/ Michael J. Ioannou
MICHAEL J. IOANNOU
Attorneys for Defendant
WIPRO, INC.

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Dated: September 1, 2011

SUSMAN GODFREY LLP
By: /s/ Stephen E. Morrissey
STEPHEN E. MORRISSEY
Attorneys for Plaintiffs
PRAVIN JAIN, RANDY HOLTHAUS,
DILIP KUKREJA, MARK WARNER, and
DOUGLAS TANNER

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A Professional Corporation
San Jose

Ropers Majeski Kohn & Bentley

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I, Michael J. Ioannou, am the ECF user whose identification and password are being used
to file this stipulation. In compliance with General Order 45.X.B, I hereby attest that the other

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signatory has concurred in this filing.
Dated: September 1, 2011

ROPERS, MAJESKI, KOHN & BENTLEY
By: /s/ Michael J. Ioannou
MICHAEL J. IOANNOU
Attorneys for Defendant
WIPRO, INC.

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[PROPOSED] ORDER

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Pursuant to the above stipulation,

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IT IS HEREBY ORDERED that the Case Management Scheduling Order filed on

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June 30, 2011 (Doc. 125), be modified to allow the depositions of the parties’ experts, non-party
Ashwin Kedia, and Deepak Chandran, to be taken on or before November 15, 2011.
IT IS FURTHER ORDERED that the Case Management Conference currently scheduled

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for September 15, 2011, be VACATED. The Case Management Conference is reset for
November 17, 2011.
Dated:

____________________________________
RICHARD SEEBORG
United States District Judge

9/1/11

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RC1/6132725.2/DPM

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CASE NO. 5:09-cv-02743-RS

Stipulation to Modify Case Management Scheduling Order; [Proposed] Order