The Board of Trustees of the Leland Stanford Junior University v. Chi-yi et al

Filing 36

ORDER GRANTING 35 Stipulation to Extend Time to Respond to First Amended Complaint filed by Chiang Yo-mei. Defendant shall have to and including April 28, 2014, in which to respond to the First Amended Complaint. Nothing contained in this sti pulation is intended to be, nor is it, an admission by Defendant as to the validity of jurisdiction or venue, nor shall it constitute a waiver of the right to object to personal jurisdiction or to venue. Signed by Judge Edward J. Davila on 4/15/2014. (ecg, COURT STAFF) (Filed on 4/15/2014)

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Attorneys for Defendant,
Chiang Yo-mei a/k/a Yo-mei Chiang

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KELLY L. KNUDSON (Bar No. CA 244445)
E-mail: [e-mail]
One Embarcadero Center, 30th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

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MANATT, PHELPS & PHILLIPS, LLP
SHARI MULROONEY WOLLMAN (Bar No. CA 137142)
E-mail: [e-mail]
11355 West Olympic Boulevard
Los Angeles, CA 90064-1614
Telephone: [phone]
Facsimile: [phone]

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4/15/2014

UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT
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SAN JOSE DIVISION
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THE BOARD OF TRUSTEES OF THE
LELAND STANFORD JUNIOR
UNIVERSITY,

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Plaintiff,
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vs.
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Chiang Fang Chi-Yi, an Individual; Chiang
Yo-mei, an Individual; Chiang Hsiaochang, an Individual; Chiang Tsai-mei, an
Individual; Chiang Yu-sung, an Individual;
Chiang Yo-lan, an Individual; Chiang Yobo, an Individual; Chiang Yo-chang, an
Individual; Chiang Yo-ching, an
Individual; Chungyan Chan, an Individual;
and Academia Historica, an entity of the
Republic of China,

No. CV 13-04383-EJD-HRL

STIPULATION TO EXTEND TIME
TO RESPOND TO FIRST
AMENDED COMPLAINT TO
APRIL 28, 2014
(L.R. 6-1)
Complaint Filed: September 20, 2013
Per Fed. R. Civ. Proc. 4(dX3)
Current Response Date: April 14, 2014
New Response Date: April 28, 2014

Defendants.

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STIPULATION AND ORDER RE
EXTENSION OF TIME

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WHEREAS Plaintiff THE BOARD OF TRUSTEES OF THE LELAND

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STANFORD JUNIOR UNIVERSITY ("Plaintiff) filed and served its First

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Amended Complaint in Interpleader pursuant to Rule 4(d)(3) of the Federal Rules

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of Civil Procedure upon Defendant Chiang Yomei a/k/a Yomei Chiang

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("Defendant") on March 7, 2014;

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WHEREAS Defendant's response to the First Amended Complaint is
currently due on April 14, 2014;

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WHEREAS Defendant requests an extension of time for Defendant to

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respond to the First Amended Complaint based on on-going negotiations between

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the parties;
WHEREAS based upon those on-going discussions Plaintiff agrees that an
extension of time is warranted;
WHEREAS Defendant Academia Historica was just recently served, and its
answer to the First Amended Complaint is not due until June 9, 2014;
WHEREAS Defendant has requested, and Plaintiff has no objection to, an

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extension for Defendant to respond to the Complaint, through and including April

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28, 2014;

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WHEREAS this is the first extension of time to respond to the First
Amended Complaint that Defendant has requested; and
WHEREAS nothing contained in this stipulation is intended to be, nor is it,

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an admission by Defendant as to the validity of jurisdiction or venue, nor shall it

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constitute a waiver of the right to object to personal jurisdiction or to venue.

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IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:
1. Defendant shall have to and including April 28, 2014, in which to
respond to the First Amended Complaint;
2. Nothing contained in this stipulation is intended to be, nor is it, an

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admission by Defendant as to the validity of jurisdiction or venue, nor shall it

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constitute a waiver of the right to object to personal jurisdiction or to venue.

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STIPULATION AND ORDER RE
EXTENSION OF TIME

3. This Stipulation is without prejudice to any party's rights, remedies,

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defenses, or positions in the case.

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Dated:

April 14, 2014

MANATT, PHELPS & PHILLIPS LLP

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By

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Dated:

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April 14, 2014

/s/
Shari Mulrooney Wollman
Attorneys for Defendant
Chiang Yo-mei (a/k/a Yo-Mei Chiang)

PILLSBURY WINTHROP SHAW
PITTMAN LLP

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By
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/S/
Mark D. Litvack
Attorneys for The Board of Trustees
of the Leland Stanford Junior
University

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312096162.1

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>s &

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STIPULATION AND ORDER RE
EXTENSION OF TIME