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Guifu Li, Meng Wang, Fang Dai, Lin Cui, and Zhong Yu, On Behalf of Themselves and All Others Similarly Situated v. A Perfect Franchise

December 14, 2010

GUIFU LI, MENG WANG, FANG DAI, LIN CUI, AND ZHONG YU, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED,
PLAINTIFFS,
v.
A PERFECT FRANCHISE, INC, A CALIFORNIA CORPORATION; ET. AL
DEFENDANTS.



The opinion of the court was delivered by: Judge: Hon. Lucy H. Koh

Richard Wahng (SBN 225672) Lee E. Sheldon (SBN 263310) Law Offices of Richard C. J. Wahng 152 Anza Street, Suite 201 Fremont, CA 94539 (510) 490-4447 Telephone (510) 490-1102 Fax Attorney for Defendants, A Perfect Day Franchise, Inc., Minjian Hand Healing Institute, Inc., Tailiang Li, and Jin Qui

CLASS ACTION

STIPULATION AND [PROPOSED ORDER] AMENDING BRIEFING TO DISMISS SCHEDULE ON DEFENDANTS' MOTION

Courtroom: 4, 5th 15 Floor

Whereas on September 3, 2010, Defendants Re-Noticed their Motion to Dismiss Proceedings and Compel Arbitration for December 2, 2010. [Dkt. No. 73.]

Whereas on November 3, 2010, Plaintiffs and Defendants stipulated to a modification of the briefing schedule to allow the parties time to complete necessary discovery. [Dkt. No. 121.]

Whereas on November 5, 2010, the Court granted the parties' stipulation and set Defendants' Motion to Dismiss Proceedings and Compel Arbitration for hearing on January 27, 2010. [Dkt. No. 123.] 24

Whereas Defendants' Reply Brief is currently due on December 16, 2010.

Whereas as December 8, 2010, Plaintiffs filed and served Defendants with Plaintiffs' Opposition to Defendants' Motion to Dismiss Proceeding and the supporting declarations of counsel and a former worker at A Perfect Day, named FENG WANG.

Whereas the parties have met and conferred and Plaintiffs have agreed to produce FENG WANG for deposition on December 17, 2010, the day after Defendants Reply Brief is currently 7 due.

Whereas the parties agree that good cause exists to modify the briefing schedule.

Whereas the parties agree to act in good faith and to complete the deposition of FENG WANG on December 17, 2010, and to further meet and confer on outstanding discovery matters.

Accordingly, the parties propose the following ...


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