Opinion
Case No. 3:11-cv-02753-JSW
10-21-2011
SUZANNE D. JACKSON, Plaintiff, v. WILLIAM FISCHER; JON SABES; STEVEN SABES; DAVID GOLDSTEEN; MARVIN SIEGEL; BRIAN CAMPION; LONNIE BOOKBINDER; CHETAN NARSUDE; MANI KULASOORIYA; JOSHUA ROSEN; UPPER ORBIT, LLC; SPECIGEN, INC.; PEER DREAMS, INC., NOTEBOOKZ, INC., ILEONARDO.COM, INC.; NEW MOON, LLC; MONVIA, LLC; and SAZANI BEACH HOTEL, Defendant.
Peter C. McMahon MCMAHON SEREPCA LLP Attorneys for Defendants William Fischer & Upper Orbit, LLC Robert Stumpf SHEPPARD MULLIN ET AL. Attorneys for Plaintiff Suzanne Jackson Tanya Herrera STEIN & LUBIN LLP Attorneys for Defendants Jon Stabes, Steven Sabes, and Marvin Siegel Brian Campion Defendant, in pro per Bret A. Puls (Pro Hac Vice) OPPENHEIMER WOLFF & DONNELLY LLP Attorneys for Defendant David Goldsteen Tom Chia-Kai Wang LAW OFFICES OF TOM CHIA-KAI WANG Attorneys for Defendants Chetan Narsude, Mani Kulasooriya, and Monvia LLC
PETER C. McMAHON (State Bar No. 161841)
KATHERINE DEBSKI (State Bar No. 271528)
MCMAHON SEREPCA LLP
Attorneys for Defendants
WILLIAM FISCHER AND UPPER ORBIT, LLC
STIPULATION AND [PROPOSED]
ORDER MODIFYING BRIEFING
SCHEDULE REGARDING
DEFENDANTS' MOTIONS TO
DISMISS
AND CONTINUING CASE
MANAGEMENT CONFERENCE
Plaintiff Suzanne Jackson ("Plaintiff") and defendants William Fischer ("Fischer"), Upper Orbit, LLC ("Upper Orbit"), Jon Sabes ("Jon Sabes"), Steven Sabes ("Steven Sabes"), David Goldsteen ("Goldsteen"), Marvin Siegel ("Siegel"), Brian Campion ("Campion"), Chetan Narsude ("Narsude"), Mani Kulasooriya ("Kulasooriya"), and Monvia, LLC ("Monvia"), collectively "Defendants", by and through their counsel, and subject to the Court's approval, stipulate as follows:
WHEREAS, on or about June 6, 2011, Plaintiff filed her Complaint;
WHEREAS, Plaintiff served her Complaint on Defendants on varying dates, as follows:
(a) On August 19, 2011, Plaintiff's complaint was served on Defendant Siegel, who stipulated with Plaintiff to extend Siegel's time to respond until October 11, 2011;
(b) On August 27, 2011, Plaintiff's complaint was served on Defendant Goldsteen, who stipulated with Plaintiff to extend his time to respond until October 11, 2011;
(c) On or about August 27, 2011, Plaintiff's complaint was served on Defendant Campion, who stipulated with Plaintiff to extend his time to
respond until October 28, 2011;
(d) On August 30, 2011, Plaintiff's complaint was served on Defendants Jon Sabes and Steven Sabes, who stipulated with Plaintiff to extend their time to respond until October 11, 2011;
(e) On August 30, 2011, Plaintiff's complaint was served on Defendants Monvia, Narsude, and Kulasooriya, who stipulated with Plaintiff to extend their time to respond until October 11, 2011;
(f) On August 31, 2011, Defendants Fischer and Upper Orbit voluntarily accepted service of Plaintiff's complaint through their Minnesota counsel, who stipulated with Plaintiff to extend Fischer's and Upper Orbit's time to respond until October 11, 2011;
(g) Defendants Bookbinder, Specigen, Peer Dreams, Notebookz, iLeonardo.com, New Moon and Joshua Rosen have been served but have not yet entered appearances and Defendant Sazani Beach Hotel has not been served;
WHEREAS, certain Defendants have filed motions to dismiss, as follows:
(a) On October 11, 2011, motions to dismiss were filed by Defendants Jon Stabes, Steven Sabes, Siegel, Fischer, Upper Orbit, Goldsteen, Kulasooriya, Narsude, and Monvia;
WHEREAS, the hearing on Defendants' Motions to Dismiss is currently set for February 24, 2012 at 9:00 a.m.;
WHEREAS, Defendants have met and conferred regarding an alternative to the briefing schedule set forth by Civil Local Rule 7-3;
WHEREAS, the parties hereby stipulate that Plaintiff's response(s) to all Motions to Dismiss set for hearing on February 24, 2012 shall now be due on November 28, 2011, and Defendants' Replies to Plaintiff's opposition(s) shall be due on December 16, 2011.
NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED BY AND BETWEEN THE PARTIES that the briefing schedule set forth above is an acceptable modification to the briefing schedule set forth under Civil Local Rule 7-3.
Peter C. McMahon
MCMAHON SEREPCA LLP
Attorneys for Defendants
William Fischer & Upper Orbit, LLC
Robert Stumpf
SHEPPARD MULLIN ET AL.
Attorneys for Plaintiff Suzanne Jackson
Tanya Herrera
STEIN & LUBIN LLP
Attorneys for Defendants Jon Stabes,
Steven Sabes, and Marvin Siegel
Brian Campion
Defendant, in pro per
Bret A. Puls (Pro Hac Vice)
OPPENHEIMER WOLFF &
DONNELLY LLP
Attorneys for Defendant David Goldsteen
Tom Chia-Kai Wang
LAW OFFICES OF TOM CHIA-KAI
WANG
Attorneys for Defendants Chetan Narsude,
Mani Kulasooriya, and Monvia LLC
In addition, the case management conference, and all associated deadlines, is CONTINUED from October 28, 2011 at 1:30 p.m. to April 27, 2012 at 1:30 p.m.
PURSUANT TO STIPULATION, IT IS SO ORDERED
The Hon. Jeffrey S. White