STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE MOTION FOR EXPEDITED DISCOVERY, MOTION TO DISMISS, AND CASE MANAGEMENT CONFERENCE

EDWARD M. CHEN, District Judge.

Pursuant to Local Rule 6-2 of the Northern District of California, Defendants Zhangyi Zhong and Dreamworld USA Inc. ("Defendants") and Plaintiff Meta Company ("Meta" or "Plaintiff") hereby stipulate to move the hearing dates and extend the briefing deadlines on Plaintiff's Motion for Expedited Discovery ("Expedited Discovery Motion") (Dkt. No. 21) and Defendant's Motion to Dismiss ("Motion to Dismiss") (Dkt. No. 38).

WHEREAS, the Parties have tentatively resolved the above-captioned lawsuit (Deol Decl., ¶ 2);

WHEREAS, the Parties wish to avoid spending additional time and effort in briefing and attending a hearing on the Expedited Discovery Motion and Motion to Dismiss, given that the case has tentatively been resolved (Deol Decl., ¶ 3);

WHEREAS the Expedited Discovery Motion is set for hearing on October 26, 2017;

WHEREAS the Motion to Dismiss is set for hearing on October 26, 2017;

WHEREAS, Plaintiff's opposition to the Motion to Dismiss is currently due on October 5, 2017;

WHEREAS, Defendants' reply in support of the Motion to Dismiss is currently due on October 12, 2017;

WHEREAS, there have been approximately four previous extensions of time (on various matters) while the Parties have endeavored to settle this case (Deol Decl., ¶ 4);

WHEREAS, counsel for both Parties agree that the requested extension would not affect any other deadlines in this case (Deol Decl., ¶ 5); and

WHEREAS, Civil Local Rule 6-2(a) of the Northern District of California states, "The parties may file a stipulation. . . requesting an order changing time that would affect the date of an event or deadline already fixed by Court order, or that would accelerate or extend time frames set in the Local Rules or in the Federal Rules."

NOW, THEREFORE, in consideration of the foregoing, the Parties agree and hereby stipulate that:

(1) the hearing on the Expedited Discovery Motion be continued to December 14, 2017;

(2) the hearing on the Motion to Dismiss be continued to December 14, 2017;

(3) Plaintiff may file its opposition to the Motion to Dismiss by no later than November 23, 2017;

(4) Defendants may file their reply to the Motion by no later than November 30, 2017;

(5) Plaintiff shall maintain its right to amend its Complaint without leave of Court until November 23, 2017;

(6) the case management conference currently set for October 26, 2017 be continued to December 14, 2017;

(7) the Parties be allowed to file their joint case management conference statement by December 7, 2017; and

(8) the Parties be allowed to file the ADR Certification and Stipulation to ADR Process/Notice of Need for ADR Phone Conference by November 23, 2017.

IT IS SO STIPULATED.

[PROPOSED] ORDER

PURSUANT TO THE PARTIES' STIPULATION, IT IS SO ORDERED.