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Securities and Exchange Commission v. King Chuen Tang A/K/A Chen Tang

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


August 26, 2011

SECURITIES AND EXCHANGE COMMISSION,
PLAINTIFF,
v.
KING CHUEN TANG A/K/A CHEN TANG,
RONALD YEE, ZISEN YU, JOSEPH SETO, MING SIU, KING S. TANG A/K/A JAMES K. TANG, AND YING KIT YU A/K/A EDDIE YU,
DEFENDANTS,
AND VENTURE ASSOCIATES FUND I, TANG
CAPITAL PARTNERS, ACCELERATION
CAPITAL PARTNERS, AMERICAN
PEGASUS LONG SHORT FUND
SEGREGATED PORTFOLIO, PING LEE TANG, KA LING LEE, YIN LEE KA, CHEUNG-TING KA, SYLVIA TSUI, DOI PING SIU, YUEN-LAI MA, LEUNG-KEE SIU, ROSALIE CHO, AND MINOR CHILD I AND MINOR CHILD II, MINOR CHILDREN OF DEFENDANT KING CHUEN TANG A/K/A CHEN TANG,
RELIEF DEFENDANTS.

The opinion of the court was delivered by: Judge: Hon. Joseph C. Spero

Jennifer D. Brandt, Texas Bar No. 00796242 Attorney for Plaintiff Phone: 817-978-6442 Fax: 817-978-4927 Jason C. Rodgers, Texas Bar No. 24005540 Securities and Exchange Commission Fort Worth District Office Burnett Plaza, Suite 1900 801 Cherry Street, Unit #18 Fort Worth, TX 76102-6882

Trial Date: February 13, 2012

STIPULATION AND [PROPOSED] ORDER EXTENDING FACT DISCOVERY DEADLINE

Date Comp. Filed: October 30, 2009

WHEREAS, on May 17, 2011, the Court issued a Further Case Management and Pretrial Order setting August 1, 2011 as the deadline to complete non-expert discovery (Dkt. No. 161);

WHEREAS, two defendants are scheduled to change their pleas (i.e., enter guilty pleas) 4 in the parallel criminal case on September 8; 5

WHEREAS, the schedules of the parties and witnesses have rendered it highly difficult 6 to complete the depositions of various defendants and third-party witnesses within the allotted 7 time; 8 9

WHEREAS, the parties respectfully submit that it is therefore in the interest of the parties to extend the non-expert discovery cutoff date until September 30, 2011; and 11

WHEREAS, extending the non-expert discovery cutoff date until September 30, 2011 2 would not have any effect on any other deadlines set by this Court;

IT IS ACCORDINGLY STIPULATED, pursuant to Civil L.R. 6-1(b), 6-2(a) and 7-12, by and between the undersigned counsel for the Parties, that:

1. The cutoff date related to non-expert discovery is extended until September 30,

2. All other dates set pursuant to the Court's Further Case Management and Pretrial Order of May 17, 2011 shall remain in place. Respectfully submitted,

ATTORNEY ATTESTATION

I hereby attest that the concurrence in the filing of this document has been obtained from the signatory indicated by a "conformed" signature (/s/) within this e-filed document.

/s/ Jennifer D. Brandt

Jennifer D. Brandt, Esq.

ORDER

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT:

1. All non-expert discovery shall be completed by September 30, 2011.

2. All other dates set pursuant to the Court's Further Case Management and Pretrial Order of May 17, 2011 shall remain in place.

Honorable JOSEPH C. SPERO United States Magistrate Judge

20110826

© 1992-2011 VersusLaw Inc.



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