1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case No. 3:16-cv-07396-EMC STIPULATION AND [PROPOSED] ORDER 

(1) RESCHEDULING CASE

MANAGEMENT CONFERENCE; AND (2)

SETTING DEADLINES TO FILE MOTION

TO DISMISS, BRIEFING SCHEDULE,

AND TO HOLD RULE 26(F)

CONFERENCE

[Counsel Provided on Signature Pages]

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

THE REGENTS OF THE UNIVERSITY OF 

CALIFORNIA, a California corporation,

Plaintiff,

v.

ROGER JINTEH ARRIGO CHEN, an individual; 

GENIA TECHNOLOGIES, INC., a Delaware 

corporation; and DOES 1-25,

Defendants.

Case No. 3:16-cv-07396-EMC

STIPULATION AND [PROPOSED] 

ORDER (1) RESCHEDULING CASE 

MANAGEMENT CONFERENCE; AND 

(2) SETTING DEADLINES TO FILE

MOTION TO DISMISS, BRIEFING

SCHEDULE, AND TO HOLD RULE

26(F) CONFERENCE

Judge: Hon. Edward M. Chen

Date: April 27, 2017

Time: 1:30 P.M.

Location: Courtroom 5, 17th Floor

Pursuant to Civil Local Rule 6-2(a), Plaintiff The Regents of the University of California 

(“Plaintiff”) and Defendants Roger Chen and Genia Technologies, Inc. (collectively, 

“Defendants”) (collectively, Plaintiff and Defendants shall be referred to herein as the “Parties”), 

by and through their counsel of record, hereby stipulate and request as follows:

Case 3:16-cv-07396-EMC Document 50 Filed 03/30/17 Page 1 of 6
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case No. 3:16-cv-07396-EMC 2 STIPULATION AND [PROPOSED] ORDER 

(1) RESCHEDULING CASE

MANAGEMENT CONFERENCE; AND (2)

SETTING DEADLINES TO FILE MOTION

TO DISMISS, BRIEFING SCHEDULE, AND

TO HOLD RULE 26(F) CONFERENCE

WHEREAS, Plaintiff filed its original complaint in this action on December 29, 2016; 

WHEREAS, pursuant to the deadline set forth in a stipulation regarding service and response 

date filed with the Court on January 10, 2017, Defendants filed a motion to dismiss on February 

27, 2017; 

WHEREAS, the motion to dismiss was noticed for hearing on April 27, 2017, with the Case 

Management Conference set for that same day; 

WHEREAS, Plaintiff filed an amended complaint on March 20, 2017;

WHEREAS, Defendants plan to file a new motion to dismiss the amended complaint;

WHEREAS, the Parties met and conferred, and agree that both Parties would benefit from 

the efficiency of holding the Case Management Conference on the same day as a hearing on 

Defendants’ motion to dismiss, provided that discovery proceeds during the pendency of the 

motion to dismiss; 

WHEREAS, the Parties further met and conferred, and agreed that both Parties would benefit 

from an extension of time beyond that contemplated by the Federal Rules of Civil Procedure and 

Local Rules to brief the motion to dismiss, as such time will allow for adequate presentation of 

the legal issues;

IT IS THEREFORE STIPULATED AND AGREED:

(1) Defendants shall file a motion to dismiss the amended complaint by April 17, 2017;

Plaintiff shall file its opposition by May 8, 2017, and Defendants shall file their reply by May 22, 

2017. 

Case 3:16-cv-07396-EMC Document 50 Filed 03/30/17 Page 2 of 6
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case No. 3:16-cv-07396-EMC 3 STIPULATION AND [PROPOSED] ORDER 

(1) RESCHEDULING CASE

MANAGEMENT CONFERENCE; AND (2)

SETTING DEADLINES TO FILE MOTION

TO DISMISS, BRIEFING SCHEDULE, AND

TO HOLD RULE 26(F) CONFERENCE

(2) The parties shall conduct their Rule 26(f) conference by April 14, 2017, so that discovery

may commence during the pendency of the motion to dismiss; 

(3) The parties respectfully request that the Court reschedule the Case Management

Conference for June 8, 2017 at 1:30 P.M. or another date on which the Court is available so that

the Case Management Conference and hearing on the motion to dismiss may be held on the same 

day. 

SO STIPULATED.

Dated: March 28, 2017.

BAKER BOTTS LLP WILMER CUTLER PICKERING 

 HALE AND DORR LLP

/s/ Stuart C. Plunkett /s/ Robert J. Gunther, Jr.

Stuart C. Plunkett (State Bar No. 187971)

stuart.plunkett@bakerbotts.com

Ariel D. House (State Bar No. 280477)

ariel.house@bakerbotts.com

BAKER BOTTS LLP

101 California Street, Suite 3070

San Francisco, California 94111

Telephone: (415) 291-6200

Facsimile: (415) 291-6300

Paul R. Morico (pro hac vice)

paul.morico@bakerbotts.com

Elizabeth Durham Flannery (pro hac vice)

liz.durham@bakerbotts.com

Thomas P. Rooney (pro hac vice)

thomas.rooney@bakerbotts.com

BAKER BOTTS LLP

One Shell Plaza

901 Louisiana Street

Robert J. Gunther, Jr. (NY SBN: 1967652) 

robert.gunther@wilmerhale.com

Omar Khan (pro hac vice)

omar.khan@wilmerhale.com

WILMER CUTLER PICKERING HALE

AND DORR LLP

7 World Trade Center

250 Greenwich Street

New York, NY 10007

Telephone: (212) 230-8800

Facsimile: (212) 230-8888

Robert M. Galvin (State Bar No. 171508)

robert.galvin@wilmerhale.com

WILMER CUTLER PICKERING HALE 

AND DORR LLP

950 Page Mill Road 

Palo Alto, CA 94304 

Telephone: 650-858-6000

Case 3:16-cv-07396-EMC Document 50 Filed 03/30/17 Page 3 of 6
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case No. 3:16-cv-07396-EMC 4 STIPULATION AND [PROPOSED] ORDER 

(1) RESCHEDULING CASE

MANAGEMENT CONFERENCE; AND (2)

SETTING DEADLINES TO FILE MOTION

TO DISMISS, BRIEFING SCHEDULE, AND

TO HOLD RULE 26(F) CONFERENCE

Houston, Texas 77002

Telephone: (713) 229-1234

Facsimile: (713) 229-1522

Counsel for Plaintiff The Regents of the 

University of California

Facsimile: 650-858-6100 

Sarah B. Petty (pro hac vice)

sarah.petty@wilmerhale.com

WILMER CUTLER PICKERING HALE 

AND DORR LLP

60 State Street 

Boston, MA 02109 

Telephone: 617-526-6000

Facsimile: 617-526-5000

Nora Q.E. Passamaneck (pro hac vice)

nora.passamaneck@wilmerhale.com

WILMER CUTLER PICKERING HALE 

AND DORR LLP

1225 17th Street, Suite 2600 

Denver, CO 80202 

Telephone: 720-274-3135

Facsimile: 720-274-3133

Counsel for Defendants Roger Jinteh Arrigo 

Chen and Genia Technologies, Inc.

Case 3:16-cv-07396-EMC Document 50 Filed 03/30/17 Page 4 of 6
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case No. 3:16-cv-07396-EMC 5 STIPULATION AND [PROPOSED] ORDER 

(1) RESCHEDULING CASE

MANAGEMENT CONFERENCE; AND (2)

SETTING DEADLINES TO FILE MOTION

TO DISMISS, BRIEFING SCHEDULE, AND

TO HOLD RULE 26(F) CONFERENCE

ATTORNEY ATTESTATION

I, Robert J. Gunther, Jr., am the ECF User whose ID and password are being used to file 

this Stipulation. In compliance with N.D. Cal. Civil. L.R. 5-1(i)(3), I hereby attest that the 

concurrence in the filing of the document has been obtained from each of the other signatories.

March 28, 2017 By: /s/ Robert J. Gunther, Jr. _______________

Robert J. Gunther, Jr.

CERTIFICATE OF SERVICE

I, Robert J. Gunther, Jr., hereby certify that on March 28, 2017, I electronically filed the 

above document with the Clerk of the Court using CM/ECF which will send electronic 

notification of such filing to all registered counsel.

March 28, 2017 By: /s/ Robert J. Gunther, Jr.

Robert J. Gunther, Jr.

Case 3:16-cv-07396-EMC Document 50 Filed 03/30/17 Page 5 of 6
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case No. 3:16-cv-07396-EMC 6 STIPULATION AND [PROPOSED] ORDER 

(1) RESCHEDULING CASE

MANAGEMENT CONFERENCE; AND (2)

SETTING DEADLINES TO FILE MOTION

TO DISMISS, BRIEFING SCHEDULE, AND

TO HOLD RULE 26(F) CONFERENCE

[PROPOSED] ORDER

IT IS ORDERED that the foregoing Stipulation is approved. The Case Management 

Conference is reset for June 8, 2017 at 1:30 P.M. in Courtroom 5, 17th Floor, San Francisco. 

Defendants shall file a motion to dismiss by April 17, 2017, Plaintiff shall file its opposition by

May 8, 2017, and Defendants shall file their reply by May 22, 2017. A hearing on the motion to 

dismiss will be set for the same day as the Case Management Conference. The parties shall 

further conduct their Rule 26(f) conference by April 14, 2017. 

DATED_______________ ________________________________

HON. EDWARD M. CHEN

UNITED STATES DISTRICT JUDGE

3/30/17

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Edward M. Chen

Case 3:16-cv-07396-EMC Document 50 Filed 03/30/17 Page 6 of 6