JOINT STATUS REPORT AND STIPULATED REQUEST TO CONTINUE FURTHER CASE MANAGEMENT CONFERENCE [PROPOSED] ORDER

EDWARD M. CHEN, District Judge.

This matter is currently set for a Further Case Management Conference on April 25, 2013. The parties submit this Joint Status Report, and a Stipulated Request to Continue the Conference because the related criminal matters are still pending.

I. STATUS REPORT

The parties submit the following status report and updated case management statement:

There are four remaining defendants in this insider trading action brought by the Securities and Exchange Commission ("Commission"), (1) Maher Kara, (2) Michael Kara, (3) Bassam Salman, and (4) Karim Bayyouk. Each of the defendants in the Commission action is also a defendant in related criminal matters. Maher Kara and Michael Kara have pled guilty but have not been sentenced (U.S. v. Kara, et al., Case No. 09-CR-0417 EMC).

The criminal matter involving Bassam Salman, U.S. v. Bassam Yacoub Salman, Case No. 11- CR-0625 EMC, is set for a 12-day jury trial to begin on June 24, 2013.

The criminal matter involving Karim Bayyouk, U.S. v. Karim Iskander Bayyouk, Case No. 12-CR-0420 EMC, is set for an 8-day trial to begin on August 26, 2013.

No trial date has been set for the Commission's civil action, and dates regarding discovery deadlines and pretrial dates have been vacated by prior orders.

The Court held a case management conference in this case on October 26, 2012, and directed that the Commission matter should continue to be stayed until the criminal matters are resolved. (Docket No. 113) The Court set a further case management for April 25, 2013, to follow the criminal trial in the Bassam Salman matter, which was set for March 2013 at the time of the conference. The Bassam Salman criminal trial date has since been continued to June 24, 2013, and the Karim Bayyouk trial has since been set for August 26, 2013.

II. STIPULATED REQUEST TO CONTINUE

Based on the above trial dates for the two related criminal matters, and the Court's direction that the civil action should be stayed until the criminal matters are resolved, the parties in this action respectfully request that the further case management conference be continued until after the criminal trial dates. The parties suggest a further case management conference be set for October 3, 2013.

In accordance with General Order 45, each of the signatories to this document have concurred in its filing, and I shall maintain records to support these concurrences.

[PROPOSED] ORDER

For the reasons stated above, and for good cause shown, the Court hereby continues the Further Case Management Conference in this case to _______________________________.10/3/13 at 10:30 a.m. The parties must file an updated Case Management Conference statement on or before