EXHIBIT A 

Case 4:16-cv-07387-KAW Document 33-1 Filed 12/19/17 Page 1 of 5
1

Wolek, Adam

From: Wolek, Adam

Sent: Tuesday, December 19, 2017 7:19 PM

To: 'Mark Figueiredo'

Cc: Ethan Solove; Lambie, Adrian T.; Czerniak, Allison E.

Subject: RE: Parkridge v. Indyzen

Mark, 

As we have stated on our prior call and below, January 4 doesn’t help us much given our travel schedule for the holidays. 

Like we offered before, we agree to work with you on whatever dates or extensions you need in turn for your reply brief 

and the hearing. But we need to know if you don’t agree to an extension because we’ll need to otherwise file so we can 

either (1) have our motion for extension be addressed by the Court before the holiday, or (2) cancel our travel plans for 

Christmas. 

Accordingly, while we’d rather not trouble the Court with such motion practice during the holidays (or cancel spending 

time with our families on Christmas), if you don’t agree to our extension request, we will have no choice but to file 

tonight. 

Regards, 

Adam 

From: Mark Figueiredo [mailto:mrf@structurelaw.com] 

Sent: Tuesday, December 19, 2017 7:07 PM 

To: Wolek, Adam <awolek@taftlaw.com> 

Cc: Ethan Solove <ESolove@structurelaw.com>; Lambie, Adrian T. <alambie@archernorris.com> 

Subject: RE: Parkridge v. Indyzen 

Adam, 

At a minimum, I can agree to January 4 with our reply due January 11. We can talk about a further extension 

tomorrow. Will that alleviate your need to file tonight? 

Mark 

From: Wolek, Adam [mailto:awolek@taftlaw.com] 

Sent: Tuesday, December 19, 2017 5:03 PM 

To: Mark Figueiredo <mrf@structurelaw.com> 

Cc: Ethan Solove <ESolove@structurelaw.com>; Lambie, Adrian T. <alambie@archernorris.com> 

Subject: RE: Parkridge v. Indyzen 

Counsel, 

To follow up on my earlier email, we of course are accordingly amenable to work with you on whatever dates that need 

to be arranged thereafter for your reply brief and the hearing. However, we need to know your response today so our 

motion for extension could be addressed by the Court before the holiday. Accordingly, while we’d rather not trouble the 

Court with such motion practice during Christmas, if you do agree to our extension request, we will have no choice but 

Case 4:16-cv-07387-KAW Document 33-1 Filed 12/19/17 Page 2 of 5
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to file tonight. 

Regards, 

Adam 

From: Wolek, Adam 

Sent: Tuesday, December 19, 2017 6:36 PM 

To: 'Mark Figueiredo' <mrf@structurelaw.com> 

Cc: Ethan Solove <ESolove@structurelaw.com>; Lambie, Adrian T. <alambie@archernorris.com> 

Subject: RE: Parkridge v. Indyzen 

Mark, 

Given that there are two major holidays imminently approaching, please let us know if you agree to an extension for a 

response to at least January 10. Again, we would rather file a stipulation than go through the necessity of motion 

practice for filing for an extension of time, particularly as we’d like to avoid burdening the Court during the upcoming 

holidays. 

Regards, 

Adam 

From: Mark Figueiredo [mailto:mrf@structurelaw.com] 

Sent: Tuesday, December 19, 2017 6:31 PM 

To: Wolek, Adam <awolek@taftlaw.com> 

Cc: Ethan Solove <ESolove@structurelaw.com>; Lambie, Adrian T. <alambie@archernorris.com> 

Subject: RE: Parkridge v. Indyzen 

Adam, 

January 18 will not work for our reply if that is the hearing date. 

Mark 

From: Wolek, Adam [mailto:awolek@taftlaw.com] 

Sent: Tuesday, December 19, 2017 4:21 PM 

To: Mark Figueiredo <mrf@structurelaw.com> 

Cc: Ethan Solove <ESolove@structurelaw.com>; Lambie, Adrian T. <alambie@archernorris.com> 

Subject: RE: Parkridge v. Indyzen 

Thanks Mark. Do you agree to the other dates (the response and reply dates) otherwise? 

Regards, 

Adam 

Case 4:16-cv-07387-KAW Document 33-1 Filed 12/19/17 Page 3 of 5
3

From: Mark Figueiredo [mailto:mrf@structurelaw.com] 

Sent: Tuesday, December 19, 2017 6:19 PM 

To: Wolek, Adam <awolek@taftlaw.com> 

Cc: Ethan Solove <ESolove@structurelaw.com>; Lambie, Adrian T. <alambie@archernorris.com> 

Subject: RE: Parkridge v. Indyzen 

Adam, 

I am told that the court does not have January 25 available. The staff person who had coordinated with the court is out 

sick today so I will confirm status tomorrow and let you know. 

Mark 

From: Wolek, Adam [mailto:awolek@taftlaw.com] 

Sent: Tuesday, December 19, 2017 4:06 PM 

To: Mark Figueiredo <mrf@structurelaw.com> 

Cc: Ethan Solove <ESolove@structurelaw.com>; Lambie, Adrian T. <alambie@archernorris.com> 

Subject: RE: Parkridge v. Indyzen 

Counsel, 

Please let us know if you agree to our proposed schedule below. If so, please let us know so we can prepare a stipulation 

for your review. We would rather file a stipulation than go through the necessity of motion practice for filing for an 

extension of time, particularly as we’d like to avoid motion practice and burdening the Court during the upcoming 

holidays. Thank you. 

Regards, 

Adam 

From: Wolek, Adam 

Sent: Tuesday, December 19, 2017 2:15 PM 

To: 'Mark Figueiredo' <mrf@structurelaw.com> 

Cc: Ethan Solove <ESolove@structurelaw.com>; Lambie, Adrian T. <alambie@archernorris.com> 

Subject: RE: Parkridge v. Indyzen 

Hi Mark, 

January 4 doesn’t help us too much given the holidays, New Year and our travel schedule. We’re ok with postponing the 

hearing date by a week. How about a response due January 10, your reply due January 18, and a hearing January 25? 

Best, 

Adam 

From: Mark Figueiredo [mailto:mrf@structurelaw.com] 

Sent: Tuesday, December 19, 2017 2:07 PM 

To: Wolek, Adam <awolek@taftlaw.com> 

Cc: Ethan Solove <ESolove@structurelaw.com>; Lambie, Adrian T. <alambie@archernorris.com> 

Subject: Parkridge v. Indyzen 

Case 4:16-cv-07387-KAW Document 33-1 Filed 12/19/17 Page 4 of 5
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Adam, 

The hearing date on our motion to compel arbitrtation is set for January 18. Accordingly, we could not extend your time 

to oppose from December 28 to January 18 without postponing the hearing. How about January 4 for your opposition 

with our reply due January 11, and the hearing proceeding on January 18? 

Mark R. Figueiredo

Structure Law Group, LLP

1754 Technology Drive, Suite 135

San Jose, CA 95110

(408) 441-7500

(408) 228-8787 fax

www.structurelaw.com

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Adam Wolek / Partner 

Taft Stettinius & Hollister LLP 

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Chicago, Illinois 60601-3713 

Tel: 312.527.4000 • Fax: 312.966.8598 

Direct: 312.836.4063 • Cell: 312.860.9006

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Case 4:16-cv-07387-KAW Document 33-1 Filed 12/19/17 Page 5 of 5