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In re Omnivision Technologies

October 6, 2006

IN RE OMNIVISION TECHNOLOGIES, INC. MASTER


The opinion of the court was delivered by: Samuel Conti United States District Judge

This Document Relates To: 04-2297-SC (Vince); ) STIPULATION AND ORDER RE 04-2298--SC (Campagnuola); 04-2385-SC ) SCHEDULED COURT DATES AND (Greenfield); 04-2410-SC (Paul Lee Associates ) DISCOVERY MATTERS LLC); 04-2419-SC (McMillan); 04-2425-SC ) (Cheung); 04-2433-SC (Gamero); 04-2474-SC ) (Van Waay); 04-2514-SC (Glantz); 04-2525-SC (Starr); 04-2570-SC (Jewell); and 04-4350-SC ) (Schroeder). STIPULATION & [PROPOSED] ORDER RE COURT ~7946100.doc DATES AND DISCOVERY MATTERS MASTER FILE STIPULATION

WHEREAS, the parties have agreed that discussions concerning possible settlement have reached a point whereby it is in the parties' best interests to defer upcoming scheduled court dates and discovery matters for a two week period ending on October 13, 2006;

WHEREAS, the parties hereby agree that Lead Plaintiffs' Motion for Class Certification and Motion to Withdraw Plaintiff Anthony P. Broccoli as Lead Plaintiff, currently scheduled for hearing on October 13, 2006 shall be continued to November 17, 2006 at 10:00 a.m., and the parties jointly request that the Court defer ruling on these motions until the rescheduled date;

WHEREAS, the time for Defendants to file their Opposition to Plaintiffs' Motion for Letter of Request for International Judicial Assistance shall be extended as the parties may agree;

WHEREAS, the parties agree that all depositions scheduled between October 2, 2006 and October 13, 2006 shall be rescheduled for mutually agreeable dates, if necessary, after October 16, 2006;

WHEREAS, the parties agree that the remaining portion of Defendants' electronic document production, consisting of privileged, redacted, and unviewable material, shall be deferred until after October 13, 2006; and

WHEREAS, the parties agree that the deadlines for exchange of expert reports will be deferred to mutually agreeable dates, with the understanding that the deposition of Gary Chen will be scheduled sufficiently in advance of submission of expert reports in this matter.

NOW THEREFORE, the parties to this action, by and through their attorneys, hereby

STIPULATE AND AGREE that upcoming scheduled court dates and discovery matters be deferred for a two week period ending on October 13, 2006.

1. Lead Plaintiffs' Motion for Class Certification and Motion to Withdraw Plaintiff Anthony P. Broccoli as Lead Plaintiff shall be continued, subject to Court approval, to November 17, 2006 at 10:00 a.m.;

2. The time for Defendants to file their Opposition to Plaintiffs' Motion for Letter of Request for International Judicial Assistance shall be extended as the parties may agree; and

3. Discovery matters, including depositions, document production, and the exchange of expert reports shall be continued to mutually agreeable dates to commence after October 16, 2006.

ORDER

Pursuant to the parties' stipulation, the Court hereby orders that the upcoming scheduled court dates and discovery matters be deferred for a two ...


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