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Joe Hand Promotions, Inc v. Ngoc Ha T. Nguyen

November 17, 2011

JOE HAND PROMOTIONS, INC.,
PLAINTIFF,
v.
NGOC HA T. NGUYEN, ET AL., DEFENDANT.



The opinion of the court was delivered by: The Honorable Lucy H. Koh United States District Court Judge

STIPULATION AND REQUEST FOR ORDER CHANGING TIME FOR EXISTING CASE SCHEDULE AS MODIFIED

Defendant Ngoc Ha T. Nguyen ("Defendant") and Plaintiff Joe Hand Promotions, Inc. ("Plaintiff") respectfully submit this stipulated Request for Order Changing Time for Existing 24 Case Schedule. 25

1. On October 13, 2011, this Court referred Defendant to the Federal Pro Bono Project and appointed Sayuri K. Sharper as Counsel for Defendant. The appointment stayed the 27 case for four weeks. 28

2. In the Case Management Order issued on October 12, 2011 (Docket Item No. 31), 2 this Court gave the parties an additional 90 days to complete the ordered settlement conference, 3 reset the deadline to amend the pleadings to November 10, 2011, and encouraged the parties to 4 meet and confer to make any further modifications to the existing schedule and file a joint 5 proposed case schedule if necessary. 6

3. The parties have scheduled a settlement conference with Magistrate Judge Grewal 7 for January 6, 2012. 8

4. The parties have further agreed to the following proposed changes to the existing 9 schedule: 10

Fact Discovery Cutoff: February 10, 2012

Last Day to File Expert Witness Designations: February 17, 2012

Expert Discovery Cutoff: March 9, 2012

Last Day to File Dispositive Motions: March 16, 2012

Pretrial Conference Date: To be determined by the Court

Court Trial Date: To be determined by the Court

5. The enlargement of time is necessary and reasonable to give the parties enough 17 time to complete fact and expert discoveries if the parties are unable to settle on or prior to January 18 6, 2012, when the settlement conference is scheduled to be completed.

6. In its first Case Management Order (Docket Item No. 17), the Court ordered the 20 parties to complete a settlement conference by October 26, 2011. In a subsequent Case 21 Management Order, the Court gave the ...


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