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Jacque Ojadidi, Dba "Xmmicro" and "Xmicro v. Xm Satellite Radio

March 28, 2011

JACQUE OJADIDI, DBA "XMMICRO" AND "XMICRO," PLAINTIFF,
v.
XM SATELLITE RADIO, INC., A DELAWARE CMC
CORPORATION; AND DOES 1 THROUGH 50, INCLUSIVE,
DEFENDANTS.



The opinion of the court was delivered by: Hon. Elizabeth D. Laportea United States Magistrate Judge

David P. Morales, Esq., SBN 191229 1 THE MORALES LAW FIRM 560 S. Winchester Blvd., Suite 500 2 San Jose, CA 95128 Telephone: (408) 850-2101 3 Facsimile: (866) 406-6080 E-Mail: dmorales@IPCounselOnline.com 4 Attorneys for Plaintiff JACQUE OJADIDI, 5 dba "XMMICRO" and "XMICRO,"

Date: April 19, 2011Time: 10:00 AM

Ctrm.: E,

15th Floor 15

Before: Hon. M. J. Elizabeth D. Laporte

STIPULATED REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES AND [PROPOSED] ORDER

Pursuant to Civil Local Rule 6-2, Defendant SIRIUS XM RADIO INC. (formerly XM Satellite Radio, Inc.)("Sirius XM") and Plaintiff JACQUE OJADIDI ("Ojadidi") (collectively, 20 the "Parties"), by and through their respective counsel, hereby file this Stipulated Request to Continue the Case Management Conference and Related Deadlines ("Stipulated Request") by 22 approximately one (1) month. This Stipulated Request is based on the Declaration of David P. 23

Morales in Support of Stipulated Request to Continue Case Management Conference and 24

Related Deadlines ("Morales Decl."), on the facts and law included in this Stipulated Request 25 and the Court's file in this matter, and on such other evidence and law as the Court may receive.

STIPULATED REQUEST

TO THE HONORABLE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: WHEREAS, on or about January 26, 2011, Sirius XM agreed to accept service of process through its undersigned counsel, see Morales Decl. at ¶2; WHEREAS, on or about January 28, 2011, Ojadidi served his First Amended Complaint ("Complaint") on Sirius XM, see id. at ¶3; 8

WHEREAS, in order to facilitate the Parties' efforts to resolve this dispute informally, Ojadidi granted Sirius XM an extension of time to answer or otherwise respond to the Complaint 10 until March 19, 2011, see id. at ¶4; 11

WHEREAS, as the Parties' efforts continued, Ojadidi granted Sirius XM a further extension of time to answer or otherwise respond to the Complaint until March 28, 2011, see id. 13 at ¶5; 14

WHEREAS, the Court's January 11, 2011 Scheduling Order set the following deadlines and Initial Case Management Conference date: fl March 29, 2011 as the parties' last day to meet and confer re: initial disclosures, early settlement, ADR process selection, and discovery plan; to file ADR ...


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