In Re Ex Parte Application of Robert E. Lee

The opinion of the court was delivered by: Jacqueline Scott Corley United States Magistrate Judge

STIPULATION AND [PROPOSED] ORDER

For an Order Pursuant to 28 U.S.C. § 1782 Judge: Hon. Jacqueline Scott Corley 17 Granting Leave to Obtain Discovery for Use Date: December 14, 2012 in Foreign Proceeding Time: 2:30 pm 18 19 20 21 Movant Khaled Ahmad Shaker Abu-Keshek ("Abu-Keshek") and Applicant Robert E. Lee 22 ("Lee") have met and conferred regarding Abu-Keshek's Motion to Quash a Subpoena in a Civil 23 Action ("Motion to Quash"). Abu-Keshek and Lee and their respective counsel have reached an agreement regarding the deposition and stipulate to the following terms: 2

1. Lee's Subpoena to Abu-Keshek to testify at a deposition in a civil action and for the 3 production of documents shall be continued from December 17, 2012 to December 26, 2012 beginning at 2:30 pm and, continuing, as necessary, to December 27, 2012 beginning at 1:00 pm.

2. Abu-Keshek agrees to promptly notify the Court that he is withdrawing his Motion to 7 Quash.

3. Abu-Keshek agrees to appear and testify on the dates set forth above. The subpoena 9 issued in this matter is continued until December 26, 2012.

Dated December 14, 2012 VAN DER HOUT, BRIGAGLIANO & NIGHTINGALE, LLP s/Stacey L. Gartland Stacey L. Gartland Attorneys for Movant Khaled Ahmad Shaker Abu-Keshek Dated December 14, 2012 STOEL RIVES, LLP 17 s/Lois O. Rosenbaum Lois O. Rosenbaum Attorneys for Applicant Robert E. Lee

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