US District Court Civil Docket as of March 22, 2013 Retrieved from the court on July 1, 2013

UNITED STATES DISTRICT COURT for the CENTRAL DISTRICT OF CALIFORNIA (Western Division - Los Angeles)

CIVIL DOCKET FOR CASE #: 2:11-cv-03701-DMG-MRW

James Rose v. Deer Consumer Products, Inc. et al Date Filed: 04/29/2011 Assigned to: Judge Dolly M. Gee Jury Demand: Plaintiff Referred to: Magistrate Judge Michael R. Wilner Nature of Suit: 850 Related Case: 2:13-cv-01682-DMG-MRW Securities/Commodities Cause: 15:78m(a) Securities Exchange Act Jurisdiction: Federal Question

Date Filed

04/29/2011

# Docket Text

1

CLASS ACTION COMPLAINT against Defendants Deer Consumer Products, Inc., Ying He, Edward Hua, Man Wai James Chiu, Zongshu Nie, Arnold Staloff, Yongmei Wang, Yuehua Xia, Qi Hua Xu, Walter Zhao. Case assigned to Judge Dolly M. Gee for all further proceedings. Discovery referred to Magistrate Judge Michael R Wilner. (Filing fee $ 350 PAID.) Jury Demanded., filed by Plaintiff James Rose. (et) Modified on 5/2/2011 (et). (ds). (Entered: 05/02/2011)

04/29/2011 21 DAY Summons Issued re Complaint - (Discovery) 1 as to Defendants Deer Consumer Products, Inc., Ying He, Edward Hua, Man Wai James Chiu, Zongshu Nie, Arnold Staloff, Yongmei Wang, Yuehua Xia, Qi Hua Xu, Walter Zhao. (et) (Entered: 05/02/2011)

04/29/2011

04/29/2011

2 CERTIFICATION AND NOTICE of Interested Parties filed by Plaintiff James Rose. (et) (ds). (Entered: 05/02/2011)

3

NOTICE OF FILING FEE DUE on Pro Hac Vice Application mailed to Jonathan Horne for Plaintiff James Rose. Your Pro Hac Vice application has not been received by the court. Please return your completed Application of Non-Resident Attorney to Appear in a Specific Case, form G-64, or a copy of the Notice of Electronic Filing of your application and the $275.00 fee and this notice immediately. Out-of-state federal government attorneys who are not employed by the U.S. Department of Justice are required to file a Pro Hac Vice application; no filing fee is required. (et) (Entered: 05/02/2011)

04/29/2011 4 INITIAL STANDING ORDER FOR CASES ASSIGNED TO JUDGE GEE by Judge Dolly M. Gee: Counsel for Plaintiffs shall serve this order immediately on all parties and/or their counsel, including any new parties to the action. If this case was removed from state court, defendant who removed the case shall serve this order on all other parties. See document for details. (gk) (Entered: 05/02/2011)

06/28/2011 5 NOTICE OF MOTION AND MOTION for Appointment of Counsel AND APPOINTMENT OF LEAD PLAINTIFF filed by MOVANT EDWARD S. GUTMAN James Rose. Motion set for hearing on 8/1/2011 at 09:30 AM before Judge Dolly M. Gee. (Attachments: # 1 Proposed Order)(Goldberg, Michael) (Entered: 06/28/2011) -

06/28/2011 6 MEMORANDUM in Support of MOTION for Appointment of Counsel AND APPOINTMENT OF LEAD PLAINTIFF 5 BY MOVANT EDWARD S. GUTMAN filed by Plaintiff James Rose. (Goldberg, Michael) (Entered: 06/28/2011)

06/28/2011 7 NOTICE OF MOTION AND MOTION for Appointment of Counsel and Lead Plaintiff filed by Movant James Rose. Motion set for hearing on 8/1/2011 at 09:30 AM before Judge Dolly M. Gee. (Attachments: # 1 Proposed Order Proposed Order)(Rosen, Laurence) (Entered: 06/28/2011)

06/28/2011 8 DECLARATION of MICHAEL GOLDBERG IN SUPPORT OF MOTION for Appointment of Counsel AND APPOINTMENT OF LEAD PLAINTIFF 5 BY MOVANT EDWARD S. GUTMAN filed by Plaintiff James Rose. (Goldberg, Michael) (Entered: 06/28/2011)

06/28/2011 9 DECLARATION of Laurence Rosen in support MOTION for Appointment of Counsel and Lead Plaintiff 7 filed by Plaintiff James Rose. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Rosen, Laurence) (Entered: 06/28/2011)

06/28/2011 10 MEMORANDUM in Support of MOTION for Appointment of Counsel and Lead Plaintiff 7 filed by Plaintiff James Rose. (Rosen, Laurence) (Entered: 06/28/2011)

06/29/2011 11 PROOF OF SERVICE Executed by Plaintiff James Rose, upon Defendant Deer Consumer Products, Inc. served on 6/23/2011, answer due 7/14/2011. Service of the Summons and Complaint were executed upon Julie Gower, Registered Agent in compliance with Federal Rules of Civil Procedure by service on a domestic corporation, unincorporated association, or public entity. Original Summons returned. (Rosen, Laurence) (Entered: 06/29/2011)

07/01/2011 12 Amendment to MOTION for Appointment of Counsel and Lead Plaintiff 7 Correcting PSLRA cerrtication filed by Plaintiff James Rose. (Rosen, Laurence) (Entered: 07/01/2011)

07/01/2011 13 DECLARATION of Laurence Rosen Amending and Correcting PSLRA Certification and Loss Calculations ISO motion for appointment as Lead Plaintiff MOTION for Appointment of Counsel and Lead Plaintiff 7 filed by Plaintiff James Rose. (Rosen, Laurence) (Entered: 07/01/2011)

07/11/2011 14 OPPOSITION to MOTION for Appointment of Counsel AND APPOINTMENT OF LEAD PLAINTIFF 5 filed by Movants Universal Invest Quality Growth, Antoine de Sejournet. (Rosen, Laurence) (Entered: 07/11/2011)

07/11/2011 15 NOTICE OF NON-OPPOSITION to MOTION for Appointment of Counsel and Lead Plaintiff 7 filed by Movant Edward S Gutman. (Goldberg, Michael) (Entered: 07/11/2011)

07/14/2011 16 STIPULATION for Extension of Time to File Response filed by Defendant Deer Consumer Products, Inc.. (Attachments: # 1 Proposed Order re Briefing Schedule)(Forman, William) (Entered: 07/14/2011)

07/14/2011 17 Certification and Notice of Interested Parties of Interested Parties filed by Defendant Deer Consumer Products, Inc., identifying Deer International Group, Ltd.; Winder Electric Group, Inc.; Delta International Ltd.; Chartis Insurance Company China, Ltd.; Deer Technology (Anhui) Co., Ltd., People's Republic of China; Anlin Technology (AnHui) Co., Ltd., People's Republic of China. (Forman, William) (Entered:

07/18/2011 18

07/14/2011)

ORDER RE BRIEFING SCHEDULE by Judge Dolly M. Gee: Upon Stipulation 16 , the Court hereby approves the briefing schedule, as follows: Time to respond to the pending Complaint is stayed. Within 45 days of the Court's ruling on the motions for appointment of lead counsel, lead plaintiff shall file a First Amended Consolidated Complaint. Defendant Deer Consumer Products, Inc. shall have 45 days from the time of service of such amended Complaint to respond. Plaintiff shall have 45 days from the service of any Motion to Dismiss, Motion 20 days from service of any such opposition to file a reply brief. (gk) (Entered: 07/18/2011)

07/21/2011 19 MINUTES (IN CHAMBERS) by Judge Dolly M. Gee: ORDER DENYING Movant Gutman's Motion to be Appointed Lead Plaintiff 5 and GRANTING De Sejournt's Motion for Appointment as Lead Plaintiff and Approval of Choice of Counsel 7 , and the 8/1/2011 hearing is VACATED.. (jp) (Entered: 07/22/2011)

09/06/2011 20

AMENDED CLASSCOMPLAINT against defendants Deer Consumer Products, Inc., Ying He, Edward Hua, Man Wai James Chiu, Zongshu Nie, Arnold Staloff, Yongmei Wang, Yuehua Xia, Qi Hua Xu, Walter Zhao amending Complaint - (Discovery),) 1 Jury Demand,filed by plaintiffs Antoine de Sejournet, Universal Invest Quality Growth, James Rose (lc) (Additional attachment(s) added on 9/8/2011: # 1 Issued Summons on Amended Complaint) (gk). (Entered: 09/07/2011)

09/06/2011 21 DAY Summons Issued re Amended Complaint, 20 as to defendants Deer Consumer Products, Inc., Ying He, Edward Hua, Man Wai James Chiu, Zongshu Nie, Arnold Staloff, Yongmei Wang, Yuehua Xia, Qi Hua Xu, Walter Zhao. (lc) (Entered: 09/07/2011)

10/21/2011 21 NOTICE of Change of Attorney Information for attorney Annah S Kim counsel for Defendant Deer Consumer Products, Inc.. Adding ANNAH S. KIM as attorney as counsel of record for Deer Consumer Products, Inc. for the reason indicated in the G-06 Notice. Filed by Defendant Deer Consumer Products, Inc. (Kim, Annah) (Entered: 10/21/2011)

10/21/2011 22 NOTICE of Change of Attorney Information for attorney Annah S Kim counsel for Defendant Deer Consumer Products, Inc.. Adding COURTNEY R. CHAVEZ as attorney as counsel of record for Deer Consumer Products, Inc. for the reason indicated in the G-06 Notice. Filed by Defendant Deer Consumer Products, Inc. (Kim, Annah) (Entered: 10/21/2011)

10/31/2011 24

NOTICE OF MOTION AND MOTION to Dismiss Case filed by defendant Deer Consumer Products, Inc.. Motion set for hearing on 1/23/2012 at 09:30 AM before Judge Dolly M. Gee. (Attachments: # 1 Request for Judicial Notice, # 2 Declaration of William H. Forman, # 3 Exhibit Exhibits A-G to Forman Declaration, # 4 Exhibit Exhibit H to Forman Declaration, # 5 Exhibit Exhibit I to Forman Declaration, # 6 Exhibit Exhibit J to Forman Declaration, # 7 Exhibit Exhibits K-N to Forman Declaration, # 8 Proposed Order)(Forman, William) (Entered: 10/21/2011)

PROOF OF SERVICE Executed by Plaintiff Antoine de Sejournet, Universal Invest Quality Growth, James Rose, upon Defendant Arnold Staloff served on 10/24/2011, answer due 11/14/2011. Service of the Summons and Complaint were executed upon Arnold Staloff in compliance with Federal Rules of Civil Procedure by personal service. Original Summons returned. (Rosen, Laurence) (Entered: 10/31/2011)

10/21/2011

23

10/31/2011 25

PROOF OF SERVICE Executed by Plaintiff Antoine de Sejournet, Universal Invest Quality Growth, James Rose, upon Defendant Walter Zhao served on 10/25/2011, answer due 11/15/2011. in compliance with Federal Rules of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons returned. (Rosen, Laurence) (Entered: 10/31/2011)

10/31/2011 26 NOTICE OF MOTION AND MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SERVE INDIVIDUAL DEFENDANTS WITH THE SUMMONS AND COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF filed by Plaintiffs James Rose, Universal Invest Quality Growth, Antoine de Sejournet. Motion set for hearing on 12/5/2011 at 09:30 AM before Judge Dolly M. Gee. (Attachments: # 1 Proposed Order)(Rosen, Laurence) (Entered: 10/31/2011)

DECLARATION of Laurence Rosen In support of MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER 26 filed by Plaintiff James Rose, Movants Universal Invest Quality Growth, Antoine de Sejournet. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3)(Rosen, Laurence) (Entered: 10/31/2011)

MEMORANDUM in Opposition to MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER 26 filed by Defendant Deer Consumer Products, Inc.. (Attachments: # 1 Declaration of Renfang (Renee) Fu, # 2 Declaration of William H. Forman, # 3 Exhibit A to Declaration of William H. Forman)(Forman, William) (Entered: 11/14/2011)

10/31/2011

27

11/14/2011 28

11/14/2011 29 NOTICE OF MOTION AND MOTION to Dismiss Case filed by Defendants Arnold Staloff, Walter Zhao. Motion set for hearing on 1/23/2012 at 09:30 AM before Judge Dolly M. Gee. (Attachments: # 1 Proposed Order)(Forman, William) (Entered: 11/14/2011)

11/14/2011 30 CERTIFICATE of Interested Parties filed by Defendant Arnold Staloff, identifying Deer International Group, Ltd.; Winder Electric Group, Inc.; Delta International Ltd; Chartis Insurance Company China, Ltd.; Deer Technology (Anhui) Co., Ltd., Peoples Republic of China; Anlin Technology (Anhui) Co., Ltd., Peoples Republic of China. (Forman, William) (Entered: 11/14/2011)

11/14/2011 31 Certificate of Interested Parties filed by Defendant Walter Zhao, identifying Deer International Group, Ltd.; Winder Electric Group, Inc.; Delta International Ltd; Chartis Insurance Company China, Ltd.; Deer Technology (Anhui) Co., Ltd., Peoples Republic of China; Anlin Technology (Anhui) Co., Ltd., Peoples Republic of China. (Forman, William) (Entered: 11/14/2011)

11/15/2011 32 MINUTE ORDER IN CHAMBERS by Judge Dolly M. Gee: On the Court's own motion, defendants Arnold Staloff's and Walter Zhao's motion to dismiss amended class action complaint 29 currently scheduled for January 23, 2012, is hereby continued to January 27, 2012 at 9:30 a.m. (smom) (Entered: 11/15/2011)

11/21/2011 33

11/21/2011 34

REPLY in support of MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER 26 filed by Plaintiff James Rose, Movants Universal Invest Quality Growth, Antoine de Sejournet. (Rosen, Laurence) (Entered: 11/21/2011)

DECLARATION of Phillip Kim in support of MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER MOTION for Leave to (1) TO EFFECT SERVICE ON THE INDIVIDUAL DEFENDANTS BY SERVING DEER CONSUMERS REGISTERED AGENT OR COUNSEL; or (2) IN THE ALTERNATIVE TO PARTIALLY LIFT THE PSLRA DISCOVERY STAY SO THAT PLAINTIFFS MAY OBTAIN CURRENT INFORMATION TO SER 26 filed by Plaintiff James Rose, Movants Universal Invest Quality Growth, Antoine de Sejournet. (Attachments: # 1 Exhibit 1-3)(Rosen, Laurence) (Entered: 11/21/2011)

11/23/2011 35 APPLICATION for attorney Phillip Kim to Appear Pro Hac Vice(PHV Fee of $325 receipt number 0973-9557284 paid.) (Rosen, Laurence) (Entered: 11/23/2011)

12/01/2011 36 MINUTE ORDER IN CHAMBERS by Judge Dolly M. Gee: Court finds that Plaintiff's Motion (1) To Effect Service on the Individual Defendants by Serving Deer Consumer's Registered Agent or Counsel; or (2) In the Alternative to Partially Lift the PSLRA Discovery Stay so that Plaintiffs may obtain current information to serve Individual Defendants with the Summons and Complaint 26 , currently scheduled for hearing on December 5, 2011, is appropriate for decision without oral argument. This motion is taken UNDER SUBMISSION and the hearing is vacated. (kpa) (Entered: 12/01/2011)

12/05/2011 37 MEMORANDUM in Opposition to MOTION to Dismiss Case 29 filed by Plaintiff James Rose, Movants Universal Invest Quality Growth, Antoine de Sejournet. (Rosen, Laurence) (Entered: 12/05/2011)

12/05/2011 38 MEMORANDUM in Opposition to MOTION to Dismiss Case 23 filed by Plaintiff James Rose, Movants Universal Invest Quality Growth, Antoine de Sejournet. (Rosen, Laurence) (Entered: 12/05/2011)

12/05/2011 39 DECLARATION of Jonathan Horne in opposition to MOTION to Dismiss Case 29 , MOTION to Dismiss Case 23 filed by Plaintiff James Rose, Movants Universal Invest Quality Growth, Antoine de Sejournet. (Attachments: # 1 Exhibit 1-6)(Rosen, Laurence) (Entered: 12/05/2011)

12/05/2011 40 REQUEST FOR JUDICIAL NOTICE re MOTION to Dismiss Case 29 , MOTION to Dismiss Case 23 filed by Plaintiff James Rose, Universal Invest Quality Growth, Antoine de Sejournet. (Attachments: # 1 Proposed Order)(Rosen, Laurence) (Entered: 12/05/2011)

12/05/2011 41 MEMORANDUM of Points and Authorities in Opposition filed by Plaintiff James Rose, Universal Invest Quality Growth, Antoine de Sejournet. DOCUMENT RELATES TO ATTACHMENT 1 OF THE FILING, THE REQUEST FOR JUDICIAL NOTICE FILED BY DEFENDANT DEER CONSUMER PRODUCTS, INC. Re: MOTION to Dismiss Case 23 (Rosen, Laurence) (Entered: 12/05/2011)

12/06/2011 42 AMENDED DOCUMENT filed by Plaintiff James Rose, Movants Universal Invest Quality Growth, Antoine de Sejournet. Amendment to Request for Judicial Notice, Request for Relief, 40 Amending Proposed Order (Attachments: # 1 Proposed Order Corrected Proposed Order)(Rosen, Laurence) (Entered: 12/06/2011)

12/19/2011 43 REQUEST FOR JUDICIAL NOTICE re MOTION to Dismiss Case 29 , MOTION to Dismiss Case 23 filed by Plaintiff James Rose, Universal Invest Quality Growth, Antoine de Sejournet. (Attachments: # 1 Proposed Order, # 2 Exhibit 1, # 3 Exhibit 2)(Rosen, Laurence) (Entered: 12/19/2011)

12/19/2011 44 ORDER by Judge Dolly M. Gee granting 35 Application to Appear Pro Hac Vice by Attorney Phillip Kim on behalf of plaintiff, designating Laurence Rosen as local counsel. (ak) (Entered: 12/20/2011)

12/22/2011 45 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Request for Judicial Notice in Opposition to Defendants Deer Consumer Products, Inc., Walter Zhao, and Arnold Staloffs' Motions to Dismiss the Amended Class Action Complaint filed 12/19/2011 43 . The following error(s) was found: The separately

12/27/2011

attached proposed order lacks at least two lines of text on the page that has the line provided for the signature of the judge, Local Rule 58-10. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (gk) (Entered: 12/22/2011)

46 REPLY IN SUPPORT OF MOTION to Dismiss Case 23 filed by Defendant Deer Consumer Products, Inc.. (Attachments: # 1 Reply in Support of Request for Judicial Notice, # 2 Declaration Supplemental Decl. of William H. Forman ISO Request for Judicial Notice ISO Motion to Dismiss, # 3 Exhibit Exhibits O - R to Supplemental Declaration of William H. Forman, # 4 Second Request for Judicial Notice ISO Motion to Dismiss, # 5 Opposition to Plaintiffs' Requests for Judicial Notice in Opposition to Motion to Dismiss, # 6 Proposed Order Granting Request for Judicial Notice of Exhibits A through N ISO Motion to Dismiss, # 7 Proposed Order Granting Second Request for Judicial Notice of Exhibits O through R ISO Motion to Dismiss)(Forman, William) (Entered: 12/27/2011)

12/29/2011 47 REPLY filed by Plaintiff James Rose, Movants Universal Invest Quality Growth, Antoine de Sejournet to Request for Judicial Notice, Request for Relief, 40 , Request for Judicial Notice, Request for Relief,,,, 43 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF REQUESTS FOR JUDICIAL NOTICE (Rosen, Laurence) (Entered: 12/29/2011)

12/29/2011 49 (IN CHAMBERS)- Order Granting Plaintiffs' Motion to Effect Service on the Individual Defendants by Serving Deer Consumer's Registered Agent or Counsel by Judge Dolly M. Gee 26 : Court finds that service of the Individual Defendants by service on Deer consumer's registered agent for service of process comports with constitutional notions of due process and is appropriate under these circumstances. Court GRANTS Plaintiffs' motion for leave to effect service on the individual defendants by serving Deer Consumer's registered agent. (kpa) (Entered: 01/03/2012)

12/30/2011 48 NOTICE of Decision: of Court in Central District of California permitting plaintiffs to serve individual defendants by service on corporate defendant, as requested by Plaintiffs in this action (Dkt. # 26) filed by Plaintiff James Rose, Universal Invest Quality Growth, Antoine de Sejournet. (Attachments: # 1 Exhibit 1)(Rosen, Laurence) (Entered: 12/30/2011)

01/13/2012 50 REPLY IN SUPPORT OF MOTION to Dismiss Case 29 filed by Defendants Arnold Staloff, Walter Zhao. (Forman, William) (Entered: 01/13/2012)

01/13/2012 51 JOINDER filed by Defendants Arnold Staloff, Walter Zhao joining in Reply (Motion related), Reply (Motion related), Reply (Motion related), Reply (Motion related) 46 , Reply (Motion related) 50 . (Forman, William) (Entered: 01/13/2012)

01/19/2012 52 MINUTE IN CHAMBERS - ORDER AND NOTICE TO ALL PARTIES by Judge Dolly M. Gee: On the Court's own motion, defendant Deer Consumer Products Inc's MOTION to Dismiss Amended Class Action Complaint 23 , currently scheduled for 1/23/2012, is hereby CONTINUED to 1/27/2012 at 9:30 AM. (jp) (Entered: 01/20/2012)

01/26/2012 53 MINUTES OF IN CHAMBERS - ORDER AND NOTICE TO ALL PARTIES by Judge Dolly M. Gee: The Court finds that defendant Deer Consumer Products, Inc.'s

Motion to Dismiss Amended Class Action Complaint 23 and Defendants Arnold Staloff's and Walter Zhao's Motion to Dismiss Amended Class Action Complaint 29 , currently scheduled for hearing on 1/27/2012, are appropriate for decision without oral argument. Accordingly, the above motions are taken UNDER SUBMISSION and the hearing is vacated. Court Reporter: Not Reported. (gk) (Entered: 01/26/2012)

01/26/2012 54 PROOF OF SERVICE Executed by Plaintiff Antoine de Sejournet, Universal Invest Quality Growth, James Rose, upon Defendant Edward Hua served on 1/18/2012, answer due 2/8/2012. Service of the Summons and Complaint were executed upon Phil Patton, a person of suitable age and discretion of the office of VAL-U-CORP Services, Inc., resident agent for DEER Consumer Products, Inc. on behalf of Edward Hua in compliance with Federal Rules of Civil Procedure by personal service. Original Summons returned. (Attachments: # 1 Supplement Order Granting Motion to Effect Service on the Individual Defendants By Serving Deer Consumer's Registered Agent or Counsel [DOC. #26])(Rosen, Laurence) (Entered: 01/26/2012)

01/26/2012 55 PROOF OF SERVICE Executed by Plaintiff Antoine de Sejournet, Universal Invest Quality Growth, James Rose, upon Defendant Man Wai James Chiu served on 1/18/2012, answer due 2/8/2012. Service of the Summons and Complaint were executed upon Phil Patton, a person of suitable age and discretion, of the office of VAL-U-CORP SERVICES, INC., resident agent for Deer Consumer Products, Inc. on Behalf of Man Wai James Chiu in compliance with Federal Rules of Civil Procedure by personal service. Original Summons returned. Service was made in compliance with Judge's Order [Doc. 49] (Rosen, Laurence) (Entered: 01/26/2012)

01/26/2012 57

PROOF OF SERVICE Executed by Plaintiff Antoine de Sejournet, Universal Invest Quality Growth, James Rose, upon Defendant Qi Hua Xu served on 1/18/2012, answer due 2/8/2012. Service of the Summons and Complaint were executed upon Phil Patton, a person of suitable age and discretion, of the offices of VAL-U-CORP SERVICES, Inc., resident agent for Deer Consumer Products, Inc. on Behalf of Qi Hua Xu in compliance with Federal Rules of Civil Procedure by personal service. Original Summons returned. Service was made in compliance with Judge's Order [Doc. 49] (Rosen, Laurence) (Entered: 01/26/2012)

PROOF OF SERVICE Executed by Plaintiff Antoine de Sejournet, Universal Invest Quality Growth, James Rose, upon Defendant Ying He served on 1/18/2012, answer due 2/8/2012. Service of the Summons and Complaint were executed upon On Phil Patton, as a person of suitable age and discretion, of the office of VAL-U-CORP SERVICES, INC., resident agent for Deer Consumer Products, Inc. on Behalf of Ying He in compliance with Federal Rules of Civil Procedure by personal service. Original Summons returned. Service was made in compliance with Judge's Order [Doc. 49] (Rosen, Laurence) (Entered: 01/26/2012)

01/26/2012

56

01/26/2012 58 PROOF OF SERVICE Executed by Plaintiff Antoine de Sejournet, Universal Invest Quality Growth, James Rose, upon Defendant Yongmei Wang served on 1/18/2012, answer due 2/8/2012. Service of the Summons and Complaint were executed upon Phil Patton, as a person of suitable age and discretion, of the office of VAL-U-CORP SERVICES, INC., resident agent for Deer Consumer Products, Inc. on Behalf of Yongmei Wang in compliance with Federal Rules of Civil Procedure by personal service. Original Summons returned. Service was made in compliance with Judge's Order [Doc. 49] (Rosen, Laurence) (Entered: 01/26/2012)

01/26/2012

01/26/2012

59

60

PROOF OF SERVICE Executed by Plaintiff Antoine de Sejournet, Universal Invest Quality Growth, James Rose, upon Defendant Yuehua Xia served on 1/18/2012, answer due 2/8/2012. Service of the Summons and Complaint were executed upon Phil Patton, as a person of suitable age and discretion, of the office of VAL-U-CORP SERVICES, INC., resident agent for Deer Consumer Products, Inc. on Behalf of Yuehua Xia in compliance with Federal Rules of Civil Procedure by personal service. Original Summons returned. Service was made in compliance with Judge's Order [Doc. 49] (Rosen, Laurence) (Entered: 01/26/2012)

PROOF OF SERVICE Executed by Plaintiff Antoine de Sejournet, Universal Invest Quality Growth, James Rose, upon Defendant Zongshu Nie served on 1/18/2012, answer due 2/8/2012. Service of the Summons and Complaint were executed upon Phil Patton, as a person of suitable age and discretion, of the office of VAL-U-CORP SERVICES, INC., resident agent for Deer Consumer Products, Inc. on Behalf of Zongshu Nie in compliance with Federal Rules of Civil Procedure by personal service. Original Summons returned. Service was made in compliance with Judge's Order [Doc. 49] (Rosen, Laurence) (Entered: 01/26/2012)

01/27/2012 61 REQUEST FOR JUDICIAL NOTICE re MOTION to Dismiss Case 29 , MOTION to Dismiss Case 23 filed by Plaintiff James Rose, Antoine de Sejournet. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Rosen, Laurence) (Entered: 01/27/2012)

01/30/2012 62 Opposition support re: MOTION to Dismiss Case 23 Opposition to Plaintiffs' January 27, 2012 Request for Judicial Notice in Opposition to Motion to Dismiss filed by Defendant Deer Consumer Products, Inc.. (Forman, William) (Entered: 01/30/2012)

01/30/2012 63 REPLY filed by Plaintiff James Rose, Movant Antoine de Sejournet to Request for Judicial Notice, Request for Relief, 61 in support of request for judicial notice (Rosen, Laurence) (Entered: 01/30/2012)

02/02/2012 64 CERTIFICATION AND NOTICE of Interested Parties filed by Defendant Ying He, identifying Deer International Group, Ltd.; Winder Electric Group, Inc.; Delta International Ltd.; Chartis Insurance Company China, Ltd.; Deer Technology (Anhui) Co., Ltd., People's Republic of China; Anlin Technology (Anhui) Co., Ltd., People's Republic of China. (Forman, William) (Entered: 02/02/2012)

02/02/2012 65 CERTIFICATION AND NOTICE of Interested Parties filed by Defendant Yuehua Xia, identifying Deer International Group, Ltd.; Winder Electric Group, Inc.; Delta International Ltd.; Chartis Insurance Company China, Ltd.; Deer Technology (Anhui) Co., Ltd., People's Republic of China; Anlin Technology (Anhui) Co., Ltd., People's Republic of China. (Forman, William) (Entered: 02/02/2012)

02/02/2012 66 CERTIFICATION AND NOTICE of Interested Parties filed by Defendant Zongshu Nie, identifying Deer International Group, Ltd.; Winder Electric Group, Inc.; Delta International Ltd.; Chartis Insurance Company China, Ltd.; Deer Technology (Anhui) Co., Ltd., People's Republic of China; Anlin Technology (Anhui) Co., Ltd., People's

I Republic of China. (Forman, William) (Entered: 02/02/2012)

02/02/2012 67 CERTIFICATION AND NOTICE of Interested Parties filed by Defendant Edward Hua, identifying Deer International Group, Ltd.; Winder Electric Group, Inc.; Delta International Ltd.; Chartis Insurance Company China, Ltd.; Deer Technology (Anhui) Co., Ltd., People's Republic of China; Anlin Technology (Anhui) Co., Ltd., People's Republic of China. (Forman, William) (Entered: 02/02/2012)

02/02/2012 68 CERTIFICATION AND NOTICE of Interested Parties filed by Defendant Qi Hua Xu, identifying Deer International Group, Ltd.; Winder Electric Group, Inc.; Delta International Ltd.; Chartis Insurance Company China, Ltd.; Deer Technology (Anhui) Co., Ltd., People's Republic of China; Anlin Technology (Anhui) Co., Ltd., People's Republic of China. (Forman, William) (Entered: 02/02/2012)

02/02/2012 69 CERTIFICATION AND NOTICE of Interested Parties filed by Defendant Yongmei Wang, identifying Deer International Group, Ltd.; Winder Electric Group, Inc.; Delta International Ltd.; Chartis Insurance Company China, Ltd.; Deer Technology (Anhui) Co., Ltd., People's Republic of China; Anlin Technology (Anhui) Co., Ltd., People's Republic of China. (Forman, William) (Entered: 02/02/2012)

02/02/2012 70

02/02/2012 71

CERTIFICATION AND NOTICE of Interested Parties filed by Defendant Man Wai James Chiu, identifying Deer International Group, Ltd.; Winder Electric Group, Inc.; Delta International Ltd.; Chartis Insurance Company China, Ltd.; Deer Technology (Anhui) Co., Ltd., People's Republic of China; Anlin Technology (Anhui) Co., Ltd., People's Republic of China. (Forman, William) (Entered: 02/02/2012)

EX PARTE APPLICATION FOR ENLARGEMENT OF TIME to File Response to Amended Class Action Complaint filed by Defendants Ying He, Edward Hua, Man Wai James Chiu, Zongshu Nie, Yongmei Wang, Yuehua Xia, Qi Hua Xu. (Attachments: # 1 Declaration of William H. Forman ISO Ex Parte Application, # 2 Exhibit 1 to Declaration of William H. Forman, # 3 Proposed Order)(Forman, William) (Entered: 02/02/2012)

Opposition In opposition to re: EX PARTE APPLICATION FOR ENLARGEMENT OF TIME to File Response to Amended Class Action Complaint 71 Plaintiffs' Opposition To China-Based Defendants EX PARTE Application To Enlarge Time to Respond To The Amended Complaint filed by Plaintiff James Rose, Movants Universal Invest Quality Growth, Antoine de Sejournet. (Rosen, Laurence) (Entered: 02/03/2012)

DECLARATION of Phillip Kim In opposition to EX PARTE APPLICATION FOR ENLARGEMENT OF TIME to File Response to Amended Class Action Complaint 71 Declaration of Phillip Kim In Opposition To China-Based Defendants Ex Parte Application To Enlarge Time To Respond To The Amended Complaint filed by Plaintiff James Rose, Movants Universal Invest Quality Growth, Antoine de Sejournet. (Attachments: # 1 Exhibit 1)(Rosen, Laurence) (Entered: 02/03/2012)

02/03/2012

72

02/03/2012

73

02/03/2012

74 ORDER GRANTING EX PARTE APPLICATION OF CHINA-BASED DEFENDANTS TO ENLARGE TIME TO RESPOND TO AMENDED CLASS ACTION by Judge Dolly M. Gee 71 . The application of the China-based Defendants for an Order extending the time for them to respond to the ACAC from February 8, 2012 until 20 days from the date this Court issues a ruling on the pending motions to dismiss of Defendants Deer Consumer Products, Inc., Walter Zhao and Arnold Staloff is GRANTED. (im) (Entered: 02/06/2012)

02/16/2012

02/16/2012

75 NOTICE OF SUPPLEMENTAL AUTHORITY DENYING IN PART MOTIONS TO DISMISS IN A SUBSTANTIALLY SIMILAR CASE filed by Plaintiffs James Rose, Universal Invest Quality Growth, Antoine de Sejournet. (Attachments: # 1 Exhibit 1)(Rosen, Laurence) (Entered: 02/16/2012)

76 SUPPLEMENT to MOTION to Dismiss Case 29 , MOTION to Dismiss Case 23 NOTICE OF SUPPLEMENTAL AUTHORITY IN SUPPORT OF MOTIONS TO

DISMISS filed by Defendants Deer Consumer Products, Inc., Arnold Staloff, Walter Zhao. (Attachments: # 1 Exhibit 1)(Forman, William) (Entered: 02/16/2012)

05/01/2012 77 SUPPLEMENT to MOTION to Dismiss Case 29 IN OPPOSITION TO MOTION filed by Movant Antoine de Sejournet. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Rosen, Laurence) (Entered: 05/01/2012)

05/16/2012 78 SUPPLEMENT to MOTION to Dismiss Case 29 , MOTION to Dismiss Case 23 supplemental authorities in opposition to motions to dismiss case filed by Movant Antoine de Sejournet. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Rosen, Laurence) (Entered: 05/16/2012)

06/06/2012 79 SUPPLEMENT to MOTION to Dismiss Case 29 , MOTION to Dismiss Case 23 in opposition to motions to dismiss case filed by Movant Antoine de Sejournet. (Attachments: # 1 Exhibit Exhibit 1, Opinion and Order)(Rosen, Laurence) (Entered: 06/06/2012)

07/16/2012 80 SUPPLEMENT to MOTION to Dismiss Case 29 , MOTION to Dismiss Case 23 SUPPLEMENTAL AUTHORITY IN OPPOSITION TO MOTION TO DISMISS filed by Movant Antoine de Sejournet. (Attachments: # 1 Exhibit 1)(Rosen, Laurence) (Entered: 07/16/2012)

07/17/2012 81 NOTICE of Supplemental Authority in Support of Motions to Dismiss filed by Defendants Deer Consumer Products, Inc., Arnold Staloff, Walter Zhao. (Forman, William) (Entered: 07/17/2012)

09/17/2012 82 SUPPLEMENT to MOTION to Dismiss Case 29 , MOTION to Dismiss Case 23 supplemental authorities in opposition to motion to dismiss case filed by Movant Antoine de Sejournet. (Attachments: # 1 Exhibit 1-5)(Rosen, Laurence) (Entered: 09/17/2012)

10/11/2012 83 NOTICE of Settlement in Principle and request to hold motions to dismiss in abeyance filed by Lead Plaintiffs Universal Invest Quality Growth, Antoine de Sejournet. (Rosen, Laurence) (Entered: 10/11/2012)

11/26/2012 84 MINUTES OF IN CHAMBERS - ORDER STAYING FURTHER PROCEEDINGS ON MOTIONS TO DISMISS AND REQUIRING THE FILING OF MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT by Judge Dolly M. Gee: On 10/11/2012, Lead Plaintiff Antoine de Sejournet and Defendants Deer Consumer Products, Inc., Arnold Staloff, and Walter Zhao filed a Notice of Settlement and Request to Hold Motions to Dismiss in Abeyance 83 , indicating that they had reached a proposed settlement of the class action and requesting that the Court hold the currently pending motions to dismiss in abeyance pending final approval of the settlement. Accordingly, IT IS ORDERED that further proceedings on the currently pending motions to dismiss 29 , 23 are hereby stayed pending final approval of the settlement. IT IS FURTHER ORDERED that no later than 12/21/2012, the Parties shall file a motion for preliminary approval of class action settlement. Court Reporter: Not Reported. (gk) (Entered: 11/26/2012)

12/21/2012 85 NOTICE OF MOTION AND MOTION for Settlement Approval of Preliminary Approval of Partial Class Action Settlement filed by Lead Plaintiffs Universal Invest Quality Growth, Antoine de Sejournet. Motion set for hearing on 2/8/2013 at 09:30 AM before Judge Dolly M. Gee. (Rosen, Laurence) (Entered: 12/21/2012)

12/21/2012 86 MEMORANDUM in Support of MOTION for Settlement Approval of Preliminary Approval of Partial Class Action Settlement 85 Unopposed filed by Movants Universal Invest Quality Growth, Antoine de Sejournet. (Rosen, Laurence) (Entered: 12/21/2012)

87 STIPULATION for Settlement for Partial Settlement, which must be approved by the Court pursuant to Fed. R. Civ. Proc. 23 filed by Lead Plaintiffs Universal Invest Quality Growth, Antoine de Sejournet. (Attachments: # 1 Proposed Order Preliminary Approval, # 2 Proposed Order Final Approval Order, # 3 Exhibit Claim Form, # 4 Exhibit Notice of Pendency, # 5 Exhibit Summary Notice)(Rosen, Laurence) (Entered: 12/21/2012)

88 NOTICE of Errata filed by Lead Plaintiffs Universal Invest Quality Growth, Antoine de Sejournet. (Rosen, Laurence) (Entered: 01/02/2013)

89 STIPULATION for Protective Order filed by Defendants Deer Consumer Products, Inc., Arnold Staloff, Walter Zhao.(Forman, William) (Entered: 01/10/2013)

90 STIPULATION for Protective Order filed by Defendants Deer Consumer Products, Inc., Arnold Staloff, Walter Zhao.(Forman, William) (Entered: 01/10/2013)

91 PROTECTIVE ORDER GOVERNING DOCUMENTS, TESTIMONY AND INFORMATION PRODUCED BY DEER by Magistrate Judge Michael R. Wilner. (See Order for further details) re Stipulation for Protective Order 90 , Stipulation for Protective Order 89 (vm) (Entered: 01/11/2013)

92

MINUTES OF Motion Hearing held before Judge Dolly M. Gee: No appearance made on behalf of Plaintiffs. The Court orders Plaintiffs' counsel to show cause why sanctions should not be imposed for his failure to appear ("OSC"). Defendants' counsel may submit a declaration by 2/15/2013 regarding the fees and costs he incurred as a result of his appearance for today's hearing. Plaintiffs' counsel shall file a written response to the OSC by 2/22/2013. The hearing on the Order to Show Cause shall be on 3/8/2013 09:30 AM before Judge Dolly M. Gee. The Motion for Preliminary Approval of the Class Action 85 is continued to 3/8/2013 at 09:30 AM before Judge Dolly M. Gee. By no later than 2/22/2013, Plaintiffs' counsel also shall file a sworn declaration in support of the motion for preliminary approval of the class action settlement. By no later than 3/1/2013, Plaintiffs' counsel shall submit a copy of the proposed order re preliminary approval of class settlement along with the proposed class notices (Exhibits A-1 and A-2) in electronic format (Word or WordPerfect) via email to chambers at dmg_chambers@cacd.uscourts.gov . The Court notes that the class notice should not require class members to file their objections or opt-out requests directly with the Court. See document for details. Court Reporter: Anne Kielwasser. (gk) (Entered: 02/08/2013)

12/21/2012

01/02/2013

01/10/2013

01/10/2013

01/11/2013

02/08/2013

02/15/2013 93 DECLARATION of William H. Forman re Motion Hearing, Link Motions to Minutes, Set/Reset Motion Hearing and R&R Deadlines, Set/Reset Deadlines/Hearings,,,,,,,,,,,,,,,,,,,, 92 filed by Defendants Deer Consumer Products, Inc., Arnold Staloff, Walter Zhao. (Forman, William) (Entered: 02/15/2013)

02/22/2013

94 DECLARATION re Motion Hearing, Link Motions to Minutes, Set/Reset Motion Hearing and R&R Deadlines, Set/Reset Deadlines/Hearings,,,,,,,,,,,,,,,,,,,, 92 filed by Movants Universal Invest Quality Growth, Antoine de Sejournet. (Attachments: # 1 Exhibit 1-4)(Rosen, Laurence) (Entered: 02/22/2013)

02/25/2013 95 NOTICE OF ERRATA filed by Movants Universal Invest Quality Growth, Antoine de

03/22/2013 97

Sejournet. correcting Declaration (non-motion), 94 (Attachments: # 1 Declaration, # 2 Exhibit 1-4)(Rosen, Laurence) (Entered: 02/25/2013)

MINUTES OF Order to Show Cause Hearing and Motion Hearing held before Judge Dolly M. Gee: Having considered Laurence M. Rosen's Declaration filed on 2/22/2013, the Court discharges the Order to Show Cause issued on 2/8/2013 92 . The Court tentatively grants Plaintiffs' Motion for Entry of Order Preliminarily Approving Settlement and Establishing Notice Procedures 85 . At the parties' request, the Court's written order will be issued in two weeks. All proceedings in this action, except those related to approval of the motion for final approval of the class settlement, are stayed. The hearing on final approval of the class settlement is set for 8/9/2013 09:30 AM before Judge Dolly M. Gee. Plaintiffs' counsel shall file their motion for attorneys' fees and incentive awards at least two weeks before Class Members' deadline for filing of objections. Court Reporter: Anne Kielwasser. (gk) (Entered: 03/08/2013)

ORDER PRELIMINARILY APPROVING SETTLEMENT AND PROVIDING FOR NOTICE by Judge Dolly M. Gee: Upon Stipulation 87 , IT IS HEREBY ORDERED that Pursuant to Rule 23 of the Federal Rules of Civil Procedure, Lead Plaintiffs are certified as the class representative on behalf of the Class and the Lead Plaintiffs' Counsel previously selected by Lead Plaintiffs and appointed by the Court is hereby appointed as Lead Counsel for the Class. A hearing (the "Final Settlement Hearing") pursuant to Federal Rule of Civil Procedure 23(e) is hereby scheduled to be held before the Court on 8/9/2013 at 9:30 AM. Lead Plaintiffs' Counsel are authorized to establish a Notice and Administration Account (as defined in the Stipulation) of $100,000. Class Members requesting exclusion from the Class shall not be entitled to receive any payment out of the Net Settlement Fund. See document for details. (gk) (Entered: 03/22/2013)

03/08/2013

96

Note: Links in this docket are stored in the PACER system ( Public Access to Court Electronic Records). PACER is a service of United States Judiciary. To view and retrieve the linked documents from PACER, you must be a registered user. To register, fill out one of the registration forms available on the PACER site. The United States Congress has given the Judicial Conference of the United States, the judicial governing body of the U.S. Federal Courts, authority to impose user fees for electronic access to case information. For more information visit the PACER site at http://pacer.psc.uscourts.gov/pacerdesc.html