District Appellate Supreme
Federal
California Northern District Court Court of Appeals for the Ninth Circuit United States Supreme Court

Rahimi v. Tesla Motors, Inc. et al
Federal Civil Lawsuit California Northern District Court, Case No. 3:13-cv-05216
District Judge Charles R. Breyer, presiding

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Last Updated January 13, 2017 at 5:41 PM ST (4.4 years ago) Request Update Request UpdateSpaceE-Mail Alert Get E-Mail Alerts

No Logo Kazim Acar, Plaintiff
No Logo Pankaj Modi, Plaintiff
No Logo Robert Rahimi, Plaintiff

Toggle Switch Represented by Glancy Binkow & Goldberg LLP

Name Phone Fax E-Mail
Space Joseph Michael Barton +1 310 201 9150 +1 310 201 9160 jbarton@glancylaw.com
Space Peter Arthur Binkow +1 310 201 9150 +1 310 201 9160 info@glancylaw.com
Space Michael Marc Goldberg +1 310 201 9150 +1 310 201 9160 mmgoldberg@glancylaw.com
Space Robert V. Prongay +1 310 201 9150 +1 310 201 9160 rprongay@glancylaw.com

Toggle Switch Represented by Pomerantz LLP

Name Phone Fax E-Mail
Space Jeremy Alan Lieberman +1 212 661 1100 +1 212 661 8665 jalieberman@pomlaw.com
Space Lesley Frank Portnoy +1 212 661 1100 +1 212 661 8665 lfportnoy@pomlaw.com
Space Matthew Laurence Tuccillo +1 212 661 1100 +1 212 661 8665 mltuccillo@pomlaw.com
No Logo William Landrum, Plaintiff
v.
Ahuja, Deepak P. Ahuja, Deepak P., Defendant
Officially listed as "Deepak Ahuja"
Tesla, Inc. Unknown Role, Tesla, Inc.
Unknown Role, Fireeye, Inc.
Musk, Elon Reeve Musk, Elon Reeve, Defendant
Officially listed as "Elon Musk"
Tesla, Inc. CEO, Tesla, Inc., October 15, 2008 - Present
Beneficial Owner, Excession LLC
SolarCity Corporation Chairman of the Board, SolarCity Corporation
Tesla, Inc. Tesla, Inc., Defendant
Officially listed as "Tesla Motors, Inc."

Toggle Switch Represented by Irell & Manella, LLP

Name Phone Fax E-Mail
Space Charles E. Elder +1 310 277 1010 +1 310 203 7199 celder@irell.com
Space David Siegel +1 310 277 1010 +1 310 203 7199 dsiegel@irell.com
No Logo Thuan Nguyen, Defendant
No Logo Edward Dahmer, Intervenor Pla

Toggle Switch Represented by Edward Dahmer

Name Phone Fax E-Mail
Space Edward Dahmer
No Logo Georgette Benita Thorton, Intervenor Pla

Toggle Switch Represented by Georgette Benita Thorton

Name Phone Fax E-Mail
Space Georgette Benita Thorton
No Logo Jimmy Jahar Thulie, Intervenor Pla

Toggle Switch Represented by Jimmy Jahar Thulie

Name Phone Fax E-Mail
Space Jimmy Jahar Thulie
No Logo Jonathan Richie, Intervenor Pla

Toggle Switch Represented by Jonathan Richie

Name Phone Fax E-Mail
Space Jonathan Richie
No Logo Lisa McKinley Tullis, Intervenor Pla

Toggle Switch Represented by Lisa McKinley Tullis

Name Phone Fax E-Mail
Space Lisa McKinley Tullis
No Logo Mary Angela Hancock, Intervenor Pla

Toggle Switch Represented by Mary Angela Hancock

Name Phone Fax E-Mail
Space Mary Angela Hancock
No Logo Melissa Elaine Webster, Intervenor Pla

Toggle Switch Represented by Melissa Elaine Webster

Name Phone Fax E-Mail
Space Melissa Elaine Webster
No Logo Wayne Albright, Intervenor Pla

Toggle Switch Represented by SCI Benner Twp.

Name Phone Fax E-Mail
Space Wayne Albright
No Logo John Magnisalis, Movant

Toggle Switch Represented by Robbins Geller Rudman & Dowd LLP

Name Phone Fax E-Mail
Space Shawn Anthony Williams +1 415 288 4545 +1 415 288 4534 swilliams@rgrdlaw.com
No Logo Thuan Nguyen, Movant

Toggle Switch Represented by Punzalan Law, PC

Name Phone Fax E-Mail
Space Mark Punzalan +1 650 362 4150 +1 650 362 4151 mark@chanpunzalan.com
Citation Section 15 U.S.C. § 78m(a)
Nature of Suit 850 - Other Statutes: Securities/Commodities/Exchange
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Legal Document (Payment Possibly Required) 89 Filed: 1/13/2017, Entered: None Clerk's Letter Spreading Mandate
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        Legal Document (Payment Possibly Required) 86 Filed: 8/3/2015, Entered: None Notice (Other)
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                Legal Document (Payment Possibly Required) 82 Filed: 3/23/2015, Entered: None Order on Motion for Leave to File
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                  Legal Document (Payment Possibly Required) 81 Filed: 3/19/2015, Entered: None Declaration in Support
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                      Legal Document (Payment Possibly Required) 79 Filed: 3/13/2015, Entered: None Reply to Opposition/Response
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                        Legal Document (Payment Possibly Required) 78 Filed: 2/28/2015, Entered: None Proposed Order
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                          Legal Document (Payment Possibly Required) 78 Filed: 2/27/2015, Entered: None
                          Proposed Order re 59 MOTION for Sanctions [Proposed Order Denying the Motion for Sanctions] by Kazim Acar, William Landrum, Pankaj Modi. (Tuccillo, Matthew) (Filed on 2/27/2015) (Entered: 02/27/2015)
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                            Legal Document (Payment Possibly Required) 77 Filed: 2/28/2015, Entered: None Declaration in Opposition
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                              Legal Document (Payment Possibly Required) 77 Filed: 2/27/2015, Entered: None
                              DECLARATION of Matthew L. Tuccillo in Opposition to 59 MOTION for Sanctions [Redacted] filed byKazim Acar, William Landrum, Pankaj Modi. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2 (Redacted), # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26)(Related document(s) 59 ) (Tuccillo, Matthew) (Filed on 2/27/2015) (Entered: 02/27/2015)
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                                Legal Document (Payment Possibly Required) 76 Filed: 2/27/2015, Entered: None Declaration in Support
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                                  Legal Document (Payment Possibly Required) 75 Filed: 2/27/2015, Entered: None Declaration in Opposition
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                                    Legal Document (Payment Possibly Required) 74 Filed: 2/27/2015, Entered: None Opposition/Response to Motion
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                                        Legal Document (Payment Possibly Required) 72 Filed: 2/25/2015, Entered: None Administrative Motion to File Under Seal
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                                          Legal Document (Payment Possibly Required) 71 Filed: 2/23/2015, Entered: None Order on Motion to Intervene
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                                              Legal Document (Payment Possibly Required) 70 Filed: 2/13/2015, Entered: None
                                              MOTION to Intervene filed by Wayne Albright, Jonathan Richie, Jimmy Jahar Thulie, Edward Dahmer, Georgette Benita Thorton, Lisa McKinley Tullis, Mary Angela Hancock, Melissa Elaine Webster. Responses due by 2/27/2015. Replies due by 3/6/2015. (mclS, COURT STAFF) (Filed on 2/13/2015) (Entered: 02/19/2015)
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                                                        Legal Document (Payment Possibly Required) 65 Filed: 1/21/2015, Entered: None Amended Document (Not Motion)
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                                                              Legal Document (Payment Possibly Required) 62 Filed: 12/24/2014, Entered: None USCA Case Number
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                                                                Legal Document (Payment Possibly Required) 61 Filed: 12/24/2014, Entered: None Stipulation and Proposed Order
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                                                                  Legal Document (Payment Possibly Required) 60 Filed: 12/19/2014, Entered: None Notice of Appeal
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                                                                    Legal Document (Payment Possibly Required) 59 Filed: 12/18/2014, Entered: None Sanctions
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                                                                          Legal Document 56 Filed: 12/5/2014, Entered: None Court Filing
                                                                          ORDER by Judge Charles R. Breyer granting (43) Motion to Dismiss in case 3:13-cv-05216-CRB (crblc2, COURT STAFF) (Filed on 12/5/2014) (Entered: 12/05/2014)
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                                                                                Legal Document (Payment Possibly Required) 53 Filed: 9/29/2014, Entered: None Motion Hearing
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                                                                                  Legal Document (Payment Possibly Required) 53 Filed: 9/26/2014, Entered: None
                                                                                  Minute Entry: Motion Hearing held on 9/26/2014 before Charles R. Breyer (Date Filed: 9/26/2014) re 43 MOTION to Dismiss Second Amended Complaint filed by Tesla Motors, Inc., Elon Musk. (Court Reporter Lydia Zinn.) (beS, COURT STAFF) (Date Filed: 9/26/2014) (Entered: 09/29/2014)
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                                                                                    Legal Document (Payment Possibly Required) 52 Filed: 9/29/2014, Entered: None Transcript Order
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                                                                                      Legal Document (Payment Possibly Required) 51 Filed: 8/29/2014, Entered: None Response ( Non Motion )
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                                                                                        Legal Document (Payment Possibly Required) 50 Filed: 8/29/2014, Entered: None Reply to Opposition/Response
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                                                                                          Legal Document (Payment Possibly Required) 49 Filed: 8/21/2014, Entered: None Order on Motion to Relate Case
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                                                                                              Legal Document (Payment Possibly Required) 47 Filed: 8/8/2014, Entered: None Request For Judicial Notice
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                                                                                                Legal Document (Payment Possibly Required) 47 Filed: 8/7/2014, Entered: None
                                                                                                Request for Judicial Notice in support of 45 Opposition/Response. filed byKazim Acar, William Landrum, Pankaj Modi. (Prongay, Robert) (Filed on 8/7/2014) Modified on 8/8/2014 (mclS, COURT STAFF). (Entered: 08/07/2014)
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                                                                                                  Legal Document (Payment Possibly Required) 46 Filed: 8/8/2014, Entered: None Declaration in Support
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                                                                                                    Legal Document (Payment Possibly Required) 46 Filed: 8/7/2014, Entered: None
                                                                                                    Declaration of Matthew L. Tuccillo in Support of 45 Opposition/Response to Motion filed byKazim Acar, William Landrum, Pankaj Modi. (Attachments: # 1 Exhibit 1 - Article, # 2 Exhibit 2 - Forum Thread, # 3 Exhibit 3 - Article)(Related document(s) 45 ) (Prongay, Robert) (Filed on 8/7/2014) (Entered: 08/07/2014)
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                                                                                                      Legal Document (Payment Possibly Required) 45 Filed: 8/8/2014, Entered: None Opposition/Response to Motion
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                                                                                                        Blank 45 Filed: 8/7/2014, Entered: None
                                                                                                        RESPONSE (re 43 MOTION to Dismiss Second Amended Complaint ) filed byKazim Acar, William Landrum, Pankaj Modi. (Prongay, Robert) (Filed on 8/7/2014) (Entered: 08/07/2014)
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                                                                                                          Legal Document (Payment Possibly Required) 44 Filed: 6/16/2014, Entered: None
                                                                                                          Request for Judicial Notice re 43 MOTION to Dismiss Second Amended Complaint filed byElon Musk, Tesla Motors, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 7, # 7 Exhibit 8, # 8 Exhibit 9, # 9 Exhibit 10, # 10 Exhibit 11)(Related document(s) 43 ) (Elder, Charles) (Filed on 6/16/2014) (Entered: 06/16/2014)
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                                                                                                            Legal Document (Payment Possibly Required) 43 Filed: 6/16/2014, Entered: None
                                                                                                            MOTION to Dismiss Second Amended Complaint filed by Elon Musk, Tesla Motors, Inc.. Motion Hearing set for 9/26/2014 10:00 AM in Courtroom 6, 17th Floor, San Francisco before Hon. Charles R. Breyer. Responses due by 8/7/2014. Replies due by 8/29/2014. (Attachments: # 1 Proposed Order)(Elder, Charles) (Filed on 6/16/2014) (Entered: 06/16/2014)
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                                                                                                              Legal Document (Payment Possibly Required) 42 Filed: 6/16/2014, Entered: None
                                                                                                              AMENDED COMPLAINT [Second Amended Class Action Complaint] against Elon Musk, Tesla Motors, Inc.. Filed byKazim Acar, William Landrum, Pankaj Modi. (Attachments: # 1 Exhibit 1 - Incident Report, # 2 Exhibit 2 - Incident Report, # 3 Exhibit 3 - Press Release, # 4 Exhibit 4 - Blog Post)(Prongay, Robert) (Filed on 6/16/2014) (Entered: 06/16/2014)
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                                                                                                                Legal Document (Payment Possibly Required) 41 Filed: 6/16/2014, Entered: None Court Filing
                                                                                                                ORDER granting 39 MOTION for Leave to File [Lead Plaintiff's Notice of Motion and Assented-To Motion for Leave to File Second Amended Class Action Complaint] filed by Kazim Acar. Robert Rahimi terminated., Signed by Judge Charles R. Breyer on 6/13/2014. (beS, COURT STAFF) (Filed on 6/16/2014) (Entered: 06/16/2014)
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                                                                                                                  Legal Document (Payment Possibly Required) 40 Filed: 6/11/2014, Entered: None
                                                                                                                  Declaration of Matthew L. Tuccillo in Support of 39 MOTION for Leave to File [Lead Plaintiff's Notice of Motion and Assented-To Motion for Leave to File Second Amended Class Action Complaint] filed byKazim Acar. (Attachments: # 1 Exhibit 1 - Proposed Second Amended Class Action Complaint, # 2 Exhibit 2 - Plaintiff Certification, # 3 Exhibit 3 - Plaintiff Certification, # 4 Exhibit 4 - Plaintiff Certification)(Related document(s) 39 ) (Prongay, Robert) (Filed on 6/11/2014) (Entered: 06/11/2014)
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                                                                                                                    Legal Document (Payment Possibly Required) 39 Filed: 6/11/2014, Entered: None
                                                                                                                    MOTION for Leave to File [Lead Plaintiff's Notice of Motion and Assented-To Motion for Leave to File Second Amended Class Action Complaint] filed by Kazim Acar. (Attachments: # 1 Proposed Order)(Prongay, Robert) (Filed on 6/11/2014) (Entered: 06/11/2014)
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                                                                                                                      Legal Document (Payment Possibly Required) 38 Filed: 5/27/2014, Entered: None Court Filing
                                                                                                                      ORDER granting 37] STIPULATION WITH PROPOSED ORDER to Extend Time To Respond to Complaint and To Modify Briefing Schedule and Page Limitations filed by Tesla Motors, Inc., et al. Set Deadlines: Motion to dismiss due by 6/16/2014. Responses due by 8/7/2014. Replies due by 8/28/2014. Motion Hearing set for 9/26/2014 10:00 AM in Courtroom 6, 17th Floor, San Francisco before Hon. Charles R. Breyer. Signed by Judge Charles R. Breyer on 5/23/2014. (beS, COURT STAFF) (Filed on 5/27/2014) (Entered: 05/27/2014)
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                                                                                                                        Legal Document (Payment Possibly Required) 37 Filed: 5/22/2014, Entered: None
                                                                                                                        STIPULATION WITH PROPOSED ORDER to Extend Time To Respond to Complaint and To Modify Briefing Schedule and Page Limitations filed by Elon Musk, Tesla Motors, Inc.. (Elder, Charles) (Filed on 5/22/2014) (Entered: 05/22/2014)
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                                                                                                                          Legal Document (Payment Possibly Required) 36 Filed: 4/17/2014, Entered: None
                                                                                                                          TRANSCRIPT ORDER by Tesla Motors, Inc. for Court Reporter Debra Pas. (Elder, Charles) (Filed on 4/17/2014) (Entered: 04/17/2014)
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                                                                                                                            Legal Document (Payment Possibly Required) 35 Filed: 4/15/2014, Entered: None
                                                                                                                            AMENDED COMPLAINT against Elon Musk, Tesla Motors, Inc.. Filed byKazim Acar, Robert Rahimi. (Attachments: # 1 Exhibit 1 - Fremont Fire Dept. Incident Report, # 2 Exhibit 2 - Palo Alto Fire Dept. Incident Report, # 3 Exhibit 3 - August 19, 2013 Press Release, # 4 Exhibit 4 - Blog Post)(Prongay, Robert) (Filed on 4/15/2014) (Entered: 04/15/2014)
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                                                                                                                              Legal Document (Payment Possibly Required) 34 Filed: 4/15/2014, Entered: None
                                                                                                                              NOTICE of Voluntary Dismissal of Defendant Deepak Ahuja Without Prejudice Pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) by Kazim Acar, Robert Rahimi (Prongay, Robert) (Filed on 4/15/2014) (Entered: 04/15/2014)
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                                                                                                                                Legal Document (Payment Possibly Required) 33 Filed: 3/11/2014, Entered: None Court Filing
                                                                                                                                Transcript of Proceedings held on 2-14-2014, before Judge Charles R. Breyer. Court Reporter/Transcriber Debra L. Pas, CRR, Telephone number (415) 431-1477/Email: Debra_Pas@cand.uscourts.gov. Per General Order No. 59 and Judicial Conference policy, this transcript may be viewed only at the Clerks Office public terminal or may be purchased through the Court Reporter/Transcriber until the deadline for the Release of Transcript Restriction.After that date it may be obtained through PACER. Any Notice of Intent to Request Redaction, if required, is due no later than 5 business days from date of this filing. Release of Transcript Restriction set for 6/9/2014. (Pas, Debra) (Filed on 3/11/2014) (Entered: 03/11/2014)
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                                                                                                                                  Legal Document (Payment Possibly Required) 32 Filed: 2/18/2014, Entered: None
                                                                                                                                  TRANSCRIPT ORDER by Kazim Acar, Robert Rahimi for Court Reporter Debra Pas. (Barton, Joseph) (Filed on 2/18/2014) (Entered: 02/18/2014)
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                                                                                                                                    Legal Document (Payment Possibly Required) 31 Filed: 2/14/2014, Entered: None
                                                                                                                                    Minute Entry: Motion Hearing held on 2/14/2014 before Charles R. Breyer (Date Filed: 2/14/2014) re 16 MOTION to Consolidate Cases and for Appointment of Lead Plaintiff filed by Thuan Nguyen, 17 MOTION to Appoint Lead Plaintiff and Lead Counsel MOTION to Consolidate Cases [Notice of Motion and Motion of Kazim Acar for Consolidation, Appointment as Lead Plaintiff, and Approval of Counsel; Memorandum of Points and Authorities in Support Thereof] filed by Kazim Acar. Amended Complaint due by 4/15/2014. (Court Reporter Debra Pas.) (beS, COURT STAFF) (Date Filed: 2/14/2014) (Entered: 02/18/2014)
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                                                                                                                                      Legal Document (Payment Possibly Required) 30 Filed: 2/14/2014, Entered: None
                                                                                                                                      NOTICE of Appearance by Joseph M. Barton (Barton, Joseph) (Filed on 2/14/2014) (Entered: 02/14/2014)
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                                                                                                                                        Legal Document (Payment Possibly Required) 29 Filed: 2/13/2014, Entered: None
                                                                                                                                        CLERKS NOTICE Continuing Motion Hearing, Set/Reset Deadlines as to 17 MOTION to Appoint Lead Plaintiff and Lead Counsel MOTION to Consolidate Cases [Notice of Motion and Motion of Kazim Acar for Consolidation, Appointment as Lead Plaintiff, and Approval of Counsel; Memorandum of Points and Authorities in Support Thereof]. Motion Hearing set for 2/14/2014 02:00 PM in Courtroom 6, 17th Floor, San Francisco before Hon. Charles R. Breyer. THIS IS A TEXT ENTRY ONLY. THERE IS NO DOCUMENT ASSOCIATED WITH THIS ENTRY. (lrcS, COURT STAFF) (Filed on 2/13/2014) (Entered: 02/13/2014)
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                                                                                                                                          Legal Document (Payment Possibly Required) 28 Filed: 1/30/2014, Entered: None Court Filing
                                                                                                                                          ORDER by Judge Charles R. Breyer granting 24 Motion for Pro Hac Vice (M. Tuccillo) (beS, COURT STAFF) (Filed on 1/30/2014) (Entered: 01/30/2014)
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                                                                                                                                            Legal Document (Payment Possibly Required) 27 Filed: 1/30/2014, Entered: None
                                                                                                                                            CLERKS NOTICE vacating Case Management Conference set for 2/7/2014 (text entry only, no document associated with this entry). (beS, COURT STAFF) (Filed on 1/30/2014) (Entered: 01/30/2014)
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                                                                                                                                              Legal Document (Payment Possibly Required) 26 Filed: 1/28/2014, Entered: None Court Filing
                                                                                                                                              ORDER by Judge Charles R. Breyer granting 23 Stipulation to extend time to respond to complaint and modify briefing schedule (beS, COURT STAFF) (Filed on 1/28/2014) (Entered: 01/28/2014)
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                                                                                                                                                Legal Document (Payment Possibly Required) 25 Filed: 1/28/2014, Entered: None
                                                                                                                                                Certificate of Interested Entities by Deepak Ahuja, Elon Musk, Tesla Motors, Inc. (Elder, Charles) (Filed on 1/28/2014) (Entered: 01/28/2014)
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                                                                                                                                                  Legal Document (Payment Possibly Required) 24 Filed: 1/28/2014, Entered: None
                                                                                                                                                  MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 305, receipt number 0971-8327527.) filed by Robert Rahimi. (Attachments: # 1 Certificate/Proof of Service)(Tuccillo, Matthew) (Filed on 1/28/2014) (Entered: 01/28/2014)
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                                                                                                                                                    Legal Document (Payment Possibly Required) 23 Filed: 1/23/2014, Entered: None
                                                                                                                                                    STIPULATION WITH PROPOSED ORDER re: Response to Complaint and Briefing Schedule filed by Deepak Ahuja, Elon Musk, Tesla Motors, Inc.. (Elder, Charles) (Filed on 1/23/2014) (Entered: 01/23/2014)
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                                                                                                                                                      Legal Document (Payment Possibly Required) 22 Filed: 1/23/2014, Entered: None
                                                                                                                                                      NOTICE of Appearance by David Siegel (Siegel, David) (Filed on 1/23/2014) (Entered: 01/23/2014)
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                                                                                                                                                        NOTICE of Appearance by Charles Edward Elder (Elder, Charles) (Filed on 1/23/2014) (Entered: 01/23/2014)
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                                                                                                                                                          Legal Document (Payment Possibly Required) 20 Filed: 1/23/2014, Entered: None
                                                                                                                                                          REPLY (re 17 MOTION to Appoint Lead Plaintiff and Lead Counsel MOTION to Consolidate Cases [Notice of Motion and Motion of Kazim Acar for Consolidation, Appointment as Lead Plaintiff, and Approval of Counsel; Memorandum of Points and Authorities in Support Thereof] ) Response Memorandum in Further Support of Motion of Kazim Acar for Consolildation, Appointment as Lead Plaintiff and Approval of Lead Counsel, and Notice of Non-Opposition filed byKazim Acar. (Lieberman, Jeremy) (Filed on 1/23/2014) (Entered: 01/23/2014)
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                                                                                                                                                            Legal Document (Payment Possibly Required) 19 Filed: 1/15/2014, Entered: None
                                                                                                                                                            Notice of Withdrawal of 16 Motion of Thuan Nguyen for Consolidation of the Actions, Appointment of Lead Plaintiff, and Approval of Lead Counsel (Punzalan, Mark) (Filed on 1/15/2014) Modified on 1/16/2014 (mclS, COURT STAFF). (Entered: 01/15/2014)
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                                                                                                                                                              Legal Document (Payment Possibly Required) 18 Filed: 1/7/2014, Entered: None
                                                                                                                                                              Declaration of Michael Goldberg in Support of 17 MOTION to Appoint Lead Plaintiff and Lead Counsel MOTION to Consolidate Cases [Notice of Motion and Motion of Kazim Acar for Consolidation, Appointment as Lead Plaintiff, and Approval of Counsel; Memorandum of Points and Authorities in Support Thereof] filed byKazim Acar. (Attachments: # 1 Exhibit A - Press Release, # 2 Exhibit B -Movant Certification, # 3 Exhibit C - Loss Chart, # 4 Exhibit D - Pomerantz Firm Resume, # 5 Exhibit E - Glancy Firm Resume)(Related document(s) 17 ) (Goldberg, Michael) (Filed on 1/7/2014) (Entered: 01/07/2014)
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                                                                                                                                                                Legal Document (Payment Possibly Required) 17 Filed: 1/7/2014, Entered: None
                                                                                                                                                                MOTION to Appoint Lead Plaintiff and Lead Counsel , MOTION to Consolidate Cases [Notice of Motion and Motion of Kazim Acar for Consolidation, Appointment as Lead Plaintiff, and Approval of Counsel; Memorandum of Points and Authorities in Support Thereof] filed by Kazim Acar. Motion Hearing set for 2/14/2014 10:00 AM in Courtroom 6, 17th Floor, San Francisco before Hon. Charles R. Breyer. Responses due by 1/21/2014. Replies due by 1/28/2014. (Attachments: # 1 Proposed Order)(Goldberg, Michael) (Filed on 1/7/2014) (Entered: 01/07/2014)
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                                                                                                                                                                  Legal Document (Payment Possibly Required) 16 Filed: 1/7/2014, Entered: None
                                                                                                                                                                  MOTION to Consolidate Cases and for Appointment of Lead Plaintiff filed by Thuan Nguyen. Motion Hearing set for 2/14/2014 10:00 AM in Courtroom 6, 17th Floor, San Francisco before Hon. Charles R. Breyer. Responses due by 1/21/2014. Replies due by 1/28/2014. (Attachments: # 1 Proposed Order, # 2 Declaration of Mark Punzalan, # 3 Exhibit A to Punzalan Declaration, # 4 Exhibit B to Punzalan Declaration, # 5 Exhibit C to Punzalan Declaration, # 6 Exhibit D to Punzalan Declaration, # 7 Certificate/Proof of Service Certification Pursuant to Local Rule 3-7(d) of Mark Punzalan, # 8 Certificate/Proof of Service Certification Pursuant to Local Rule 3-7(d) of Nicholas Porritt)(Punzalan, Mark) (Filed on 1/7/2014) (Entered: 01/07/2014)
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                                                                                                                                                                    Legal Document (Payment Possibly Required) 15 Filed: 1/3/2014, Entered: None
                                                                                                                                                                    Order by Hon. Charles R. Breyer granting 14 Motion to Relate Case(s): C-13-5438 WHO is hereby related to C-13-5216 CRB.(tlS, COURT STAFF) (Filed on 1/3/2014) (Entered: 01/03/2014)
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                                                                                                                                                                      Legal Document (Payment Possibly Required) 14 Filed: 12/27/2013, Entered: None
                                                                                                                                                                      MOTION to Relate Case Administrative Motion to Consider Whether Cases Should Be Related Pursuant to Civil Local Rules 3-12 and 7-11 filed by John Magnisalis. (Attachments: # 1 Declaration of Shawn A. Williams in Support, # 2 Proposed Order)(Williams, Shawn) (Filed on 12/27/2013) (Entered: 12/27/2013)
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                                                                                                                                                                        Legal Document (Payment Possibly Required) 13 Filed: 12/20/2013, Entered: None
                                                                                                                                                                        WAIVER OF SERVICE Returned Executed filed by Robert Rahimi. Service waived by Tesla Motors, Inc. waiver sent on 12/19/2013, answer due 2/18/2014. (Lieberman, Jeremy) (Filed on 12/20/2013) (Entered: 12/20/2013)
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                                                                                                                                                                          Legal Document (Payment Possibly Required) 12 Filed: 12/20/2013, Entered: None
                                                                                                                                                                          WAIVER OF SERVICE Returned Executed filed by Robert Rahimi. Service waived by Deepak Ahuja waiver sent on 12/19/2013, answer due 2/18/2014. (Lieberman, Jeremy) (Filed on 12/20/2013) (Entered: 12/20/2013)
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                                                                                                                                                                            Legal Document (Payment Possibly Required) 6 Filed: 11/12/2013, Entered: None
                                                                                                                                                                            Summons Issued as to Deepak Ahuja, Elon Musk, Tesla Motors, Inc. (mclS, COURT STAFF) (Entered: 11/12/2013)
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                                                                                                                                                                              Legal Document (Payment Possibly Required) 11 Filed: 12/20/2013, Entered: None
                                                                                                                                                                              WAIVER OF SERVICE Returned Executed filed by Robert Rahimi. Service waived by Elon Musk waiver sent on 12/19/2013, answer due 2/18/2014. (Lieberman, Jeremy) (Filed on 12/20/2013) (Entered: 12/20/2013)
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                                                                                                                                                                                Legal Document (Payment Possibly Required) 5 Filed: 11/12/2013, Entered: None
                                                                                                                                                                                ADR SCHEDULING ORDER: Case Management Statement due by 1/31/2014. Case Management Conference set for 2/7/2014 08:30 AM. (Attachments: # 1 Standing Order)(mclS, COURT STAFF) (Filed on 11/12/2013) (Entered: 11/12/2013)
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                                                                                                                                                                                  Legal Document (Payment Possibly Required) 10 Filed: 12/17/2013, Entered: None Court Filing
                                                                                                                                                                                  ORDER by Judge Charles R. Breyer granting 8 Motion for Pro Hac Vice (L F Portnoy) (beS, COURT STAFF) (Filed on 12/17/2013) (Entered: 12/17/2013)
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                                                                                                                                                                                    Legal Document (Payment Possibly Required) 4 Filed: 11/8/2013, Entered: None
                                                                                                                                                                                    Case assigned to Hon. Charles R. Breyer. Counsel for plaintiff or the removing party is responsible for serving the Complaint or Notice of Removal, Summons and the assigned judge's standing orders and all other new case documents upon the opposing parties. For information, visit E-Filing A New Civil Case at http://cand.uscourts.gov/ecf/caseopening.Standing orders can be downloaded from the court's web page at www.cand.uscourts.gov/judges. Upon receipt, the summons will be issued and returned electronically. Counsel is required to send chambers a copy of the initiating documents pursuant to L.R. 5-1(e)(7). A scheduling order will be sent by Notice of Electronic Filing (NEF) within two business days. (sv, COURT STAFF) (Filed on 11/8/2013) (Entered: 11/08/2013)
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                                                                                                                                                                                      Legal Document (Payment Possibly Required) 9 Filed: 12/17/2013, Entered: None Court Filing
                                                                                                                                                                                      ORDER by Judge Charles R. Breyer granting 7 Motion for Pro Hac Vice (J A Lieberman) (beS, COURT STAFF) (Filed on 12/17/2013) (Entered: 12/17/2013)
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                                                                                                                                                                                        Legal Document (Payment Possibly Required) 3 Filed: 11/8/2013, Entered: None
                                                                                                                                                                                        Statement re 1 Complaint [Certification of Lionel Z. Glancy Pursuant to Northern District Civil Local Rule 3-7(d)] by Robert Rahimi. (Glancy, Lionel) (Filed on 11/8/2013) (Entered: 11/08/2013)
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                                                                                                                                                                                          Legal Document (Payment Possibly Required) 8 Filed: 12/11/2013, Entered: None
                                                                                                                                                                                          MOTION and [PROPOSED] ORDER for leave to appear in Pro Hac Vice ( Filing fee $ 305, receipt number 0971-8222014.) filed by Robert Rahimi. (Attachments: # 1 Exhibit Certificate of Good Standing, # 2 Certificate of Service)(Portnoy, Lesley) (Filed on 12/11/2013) Modified on 12/12/2013 (aaaS, COURT STAFF). (Entered: 12/11/2013)
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                                                                                                                                                                                            Legal Document (Payment Possibly Required) 2 Filed: 11/8/2013, Entered: None
                                                                                                                                                                                            Proposed Summons. (Glancy, Lionel) (Filed on 11/8/2013) (Entered: 11/08/2013)
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                                                                                                                                                                                              Legal Document (Payment Possibly Required) 7 Filed: 12/11/2013, Entered: None
                                                                                                                                                                                              MOTION and [PROPOSED] ORDER for leave to appear in Pro Hac Vice ( Filing fee $ 305, receipt number 0971-8221959.) filed by Robert Rahimi. (Attachments: # 1 Exhibit Certificate of Good Standing, # 2 Certificate of Service)(Lieberman, Jeremy) (Filed on 12/11/2013) Modified on 12/12/2013 (aaaS, COURT STAFF). (Entered: 12/11/2013)
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                                                                                                                                                                                                Blank 1 Filed: 11/8/2013, Entered: None
                                                                                                                                                                                                COMPLAINT against Deepak Ahuja, Elon Musk, Tesla Motors, Inc. ( Filing fee $ 400, receipt number 0971-8148324.). Filed byRobert Rahimi. (Attachments: # 1 Civil Cover Sheet)(Glancy, Lionel) (Filed on 11/8/2013) (Entered: 11/08/2013)
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