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JOINT STATUS REPORT

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Mark R. Figueiredo, Esq. (Cal. SBN 178850)

Ethan G. Solove, Esq. (Cal. SBN 308026)

Austin T. Jackson, Esq. (Cal. SBN 317538)

STRUCTURE LAW GROUP, LLP

1754 Technology Drive, Suite 135

San Jose, California 95110

Telephone: (408) 441-7500

Facsimile: (408) 441-7501 

Attorneys for Defendants 

INDYZEN, INC. and PRAVEEN NARRA KUMAR

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

PARKRIDGE LIMITED, a Hong Kong 

corporation, by Mabel Mak, and MABEL MAK, 

an individual,

Plaintiffs,

v.

INDYZEN, INC., a California corporation, and 

PRAVEEN NARRA KUMAR, an individual,

Defendants.

Case No. 4:16-cv-07387-JSW

JOINT STATUS REPORT 

Date: October 10, 2018

Time: N/A

Dept.: N/A

Judge: Hon. Jeffrey S. White

The Parties respectfully submit the following Joint Status Report pursuant to Docket 24 in the 

above captioned case. The above-captioned case is stayed pursuant to the April 18, 2017 Order. Dkt. 

24, at 9-10. The Parties are participating in arbitration pursuant to the Court’s Order, which is 

currently pending.

Defendants’ Statement Only

On April 13, 2018, the Court ordered Randy Dobson, California Management Group a/k/a

CMG.Asia, California Fitness & Yoga Centers, F8 Vietnam Company Limited, and Boon Global

Limited (the “Additional Cross-Respondents) “to join the related arbitration for this case in order that 

the arbitrator may decide whether to allow counterclaims against them proceed.” On April 25, 2018, 

the Arbitrator issued an order allowing the counterclaims against the Additional Cross-Respondents 

to proceed, and the Arbitration has been continuing with them as well as the Plaintiffs and Defendants 

Case 4:16-cv-07387-JSW Document 72 Filed 10/10/18 Page 1 of 2
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JOINT STATUS REPORT

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ever since. On July 30, 2018, the Arbitrator issued an order denying the Additional CrossRespondents’ motion to dismiss in its entirety. 

The Parties are currently in the discovery phase of the Arbitration, with percipient witness 

depositions ordered by the Arbitrator to be wrapped up by the end of October and expert witness 

depositions to be wrapped up by the end of November. An evidentiary hearing is scheduled for late 

January.

Plaintiffs’ Statement Only

Plaintiffs believe that Defendants’ separate statements and characterizations are unnecessary, 

and are nevertheless inaccurate and incomplete. While Defendants state that the Arbitrator’s April 

25, 2018 order “allow[ed] the counterclaims . . . to proceed,” the Arbitrator actually ruled that the 

Additional Cross-Respondents are entitled to formal notice and an opportunity to raise jurisdictional 

objections and defenses. Indeed, the Arbitrator has stated that he will revisit Defendants’ 

counterclaims. 

DATED: October 10, 2018 Respectfully submitted,

By: /s/ Adam Wolek

Adam Wolek (pro hac vice)

Taft Stettinius & Hollister LLP

111 E. Wacker Drive, Suite 2800

Chicago, Illinois 60601-3713

Tel: 312.836.4063 

Fax: 312.966.8598

awolek@taftlaw.com

LAW OFFICES OF DAVID A. MAKMAN 

David A. Makman, SBN 178195

david@makmanlaw.com

Attorneys for PLAINTIFFS

DATED: October 10, 2018 Respectfully submitted,

STRUCTURE LAW GROUP, LLP

By: /s/ Ethan G. Solove

Ethan G. Solove, Esq.

Email: ESolove@structurelaw.com

Attorneys for DEFENDANTS

Case 4:16-cv-07387-JSW Document 72 Filed 10/10/18 Page 2 of 2