Order: FAIZAN BUZDAR vs. CONVO CORPORATION, et al

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UW    Brian T. Hafter (CA State Bar No. 173151)
      brian. hafier@rimonlaw.com
                                                                                     FILED
                                                                               SAN MATEO COUNTY
      RIMON P.C.
      One Embarcadero Center #400                                                            Pr 2 0 2018
      San Francisco, CA 94111
      Telephone:    (415) 810-8403                                             Cle
                                                                      By
                                                                                          ‘DEP!
      Attorneys for Plaintiff and Cross-Defendant
      FAIZAN BUZDAR




                                            CALIFORNIA SUPERIOR COURT

                                        FOR THE COUNTY OF SAN MATEO
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 12   FAIZAN BUZDAR,                                        CASE NO. 17 CIV 03337
 13                            Plaintiff,                   Stipulation and [Proposed] Order to Advance
 14           Vv.
                                                            Hearing Date of Plaintiffs Motion to Compel
 15                                                         Date:       September 20, 2018
      CONVO CORPORATION, and DOES 1
 16   through 10, inclusive,                                Time: 2:00 p.m.
                                                            Dept:       Law and Motion
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                               Defendant.
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                                            wannenen:   =
                                                                    Order Denying
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                                                               “TOO
                                                                    1396098
      CONVO CORPORATION,
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 21                            Cross-Complainant,                          -         --           -   So   le
 22           Vv.

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      FAIZAN BUZDAR, and DOES 1 through 10,
 24   inclusive,

 25                            Cross-Defendant.
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The parties, through their respective counsel, hereby stipulate and agree as follows:
              1         On September 14, 2018, Plaintiff Faizan Buzdar (“Plaintiff”) filed and served a

     Motion to Compel Production of Responsive Documents and Further Written Responses to Requests

     for Production of Documents, and Request for Monetary Sanctions (the “Motion”).

              2         Plaintiffs counsel noticed the Motion to be heard on October 12, 2018, which

     Plaintiffs counsel represents was the first hearing date available with the Court.
              3         In order to accommodate Plaintiff’s desire for the motion to be heard on an expedited

     basis, and to avoid a contested ex parte appearance, the parties have agreed that the Motion will be
     heard as follows:
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                        A        Opposition date — September 26, 2018
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                        B.       Reply date — September 27, 2018
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                        Cc.      Hearing date — September 28, 2018, 9:00 a.m., Law and Motion Department
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              IT IS SO STIPULATED.
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15   Dated: September 20, 2018                             Rimon P.C.
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18                                                         By
                                                           Bri       Hafter
19                                                         Att   ys for Plaintiff and Cross-Defendant
20                                                         FAIZAN BUZDAR

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     Dated:       September 20, 2018                       NOSSAMAN LLP




                                                           (reatdh wil
                                                           PATRICK J. RICHARD
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                                                                                Patfick J. Richard
25                                                         Attorneys for Defendant and Cross-Complainant
26                                                         CONVO CORPORATION

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                                                Faizan Buzdar v. Convo Corporation
                      Stipulation and [Proposed] Order to Advance Hearing Date of Plaintiff's Motion to Compel
1   IT IS SO ORDERED:
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                                                                       DENIED
                                                                         SUSAN GREENBERG
         Dated:   September 20, 2018                       By
                                                                     Judge of the Superior Court




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                                                 Faizan Buzdar v. Convo Corporation
                      Stipulation and [Proposed] Order to Advance Hearing Date of Plaintiff's Motion to Compe]