Motion for Extension of Time to Respond to Defendants’ Motion to Compel Arbitration of Five Newly Named Parties Until After the Holidays 

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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 

DAVID A. MAKMAN (SBN 178195)

david@makmanlaw.com

LAW OFFICES OF DAVID A. MAKMAN 

655 Mariner’s Island Blvd, Suite 306 

San Mateo, CA 94404 

Telephone: (650) 242-1560 

Facsimile: (408) 716-3052 

Attorneys for Plaintiffs 

Parkridge and Mabel Mak 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

On Behalf of 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. 16-cv-07387-KAW 

MOTION FOR EXTENSION OF TIME TO 

RESPOND TO DEFENDANTS’ MOTION 

TO COMPEL ARBITRATION OF FIVE 

NEWLY-NAMED PARTIES UNTIL 

AFTER THE HOLIDAYS 

Date: December 19, 2017 

Time: N/A 

Dept.: N/A 

Judge: Hon. Kandis A. Westmore 

Plaintiffs Parkridge et al. respectfully request the Court extend the deadline to respond to 

Defendants Motion to Compel Arbitration of Five Newly-Named Parties until at least January 18, 

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

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2018.1 Defendants’ filing was made as a motion to compel (Dkt. 32), originally triggering an 

electronically-set response date of December 28, 2017. Plaintiffs’ counsel requested an extension 

from Defendants’ counsel because that briefing schedule would require counsel to work over 

Christmas, among other reasons. See Exhibit A. Defendants’ counsel agreed to a response date of 

at least January 4, 2018. See id. However, that due date would still interfere with the upcoming 

holidays and Plaintiffs’ counsels’ travel for the holidays because a Response being due right after 

the holidays would effectively require counsel to work over the holidays. Plaintiffs’ counsel 

requested additional time to avoid interfering with the holidays, among other reasons. See id. 

Furthermore, more than two weeks is needed to address all of the complex issues raised in 

Defendants’ motion, including, among other issues, whether each of the five newly-named entities 

were signatories to an agreement premised on an alter-ego theory (each would have to undergo a 

separate alter-ego analysis), whether the Court properly has jurisdiction over each of the five newlynamed entities, and whether each of the five newly-named entities Consents to Magistrate Judge 

Jurisdiction. 

Moreover, given that the five newly-named parties are all located in Asia, the time 

difference and logistical communication issues further exacerbate delays in getting information, and 

sign off, to respond and address each of the relevant issues. 

For these, and other reasons, Plaintiffs’ respectfully request the Court enter an order 

extending the deadline from January 4, 2018, to respond to at least January 18, 2018. 

 

1

 This request for an extension of time is made without prejudice to any defenses or arguments, and all rights 

are expressly reserved, including, but not limited to, challenging the propriety of the jurisdiction before this 

Court over the newly-named parties, the propriety of these disputes before this Court, the propriety of the 

process, the sufficiency of the allegations made, and the underlying facts and law, and reserve all rights 

hereto. 

Case 4:16-cv-07387-KAW Document 33 Filed 12/19/17 Page 2 of 4
 

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DATED: December 19, 2017 Respectfully submitted, 

By: /s/ Adam Wolek 

Adam Wolek (pro hac vice) 

Taft Stettinius & Hollister LLP 

111 E. Wacker Drive, Suite 2800 

Chicago, Illinois 60601 

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 

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

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CERTIFICATE OF SERVICE

The undersigned certifies that, on December 19, 2017, he caused this document to be 

electronically filed with the Clerk of Court using the CM/ECF system, which will send notification 

of filing to counsel of record for each party. 

Dated: December 19, 2017 Taft Stettinius & Hollister LLP 

 

By:/s/ Adam Wolek 

 Adam Wolek 

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