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BOIES SCHILLER FLEXNER LLP 

Case No. 17-CV-00223-RS

STIPULATION TO CONTINUE HEARING DATE

AND ASSOCIATED BRIEFING DEADLINES OF MOTION TO CONSOLIDATE

BOIES SCHILLER FLEXNER LLP 

MICHAEL V SCHAFLER, State Bar No. 212164 

 mschafler@bsfllp.com 

LENNETTE W. LEE, State Bar No. 263023 

 llee@bsfllp.com

725 South Figueroa Street, 31st Floor 

Los Angeles, California 90017-5524 

Telephone: (213) 629-9040 

Facsimile: (213) 629-9022 

Attorneys for Interested Parties 

LI FENG, MA XIAO, GUO WENJING, 

YUAN ZHILIN, MA SONGJUN, LU 

CHUAN, MA WENLI, LIU QI, LI 

HONGMEI, WEI JIANJUN, AND FAN 

SHUYI 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

SECURITIES AND EXCHANGE 

COMMISSION, 

Plaintiff, 

v. 

SAN FRANCISCO REGIONAL CENTER 

LLC, et al., 

Defendants. 

 Case No. 17-CV-00223-RS 

STIPULATION TO CONTINUE 

HEARING DATE AND ASSOCIATED 

BRIEFING DEADLINES OF MOTION 

FOR ORDER CONSOLIDATING THE 

RECEIVERSHIP ENTITIES FOR 

PURPOSES OF DISTRIBUTION FILED 

BY RECEIVER SUSAN L. UECKER; 

DECLARATION OF MICHAEL V 

SCHAFLER; AND [PROPOSED] ORDER

The Honorable Richard Seeborg 
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BOIES SCHILLER FLEXNER LLP 

 -1- Case No. 17-CV-00223-RS

STIPULATION TO CONTINUE HEARING DATE 

AND ASSOCIATED BRIEFING DEADLINES OF MOTION TO CONSOLIDATE

Interested Parties Li Feng, Ma Xiao, Guo Wenjing, Yuan Zhilin, Ma Songjun, 

Lu Chuan, Ma Wenli, Liu Qi, Li Hongmei, Wei Jianjun, and Fan Shuyi 

(collectively, “CallSocket, L.P. Investors”), and Receiver Susan L. Uecker (together 

with CallSocket, L.P. Investors, the “Parties”), by and through their counsel of 

record, stipulate and agree as follows: 

WHEREAS, on February 28, 2019, Receiver Susan L. Uecker (“Receiver”) 

filed a Motion for Order Consolidating the Receivership Entities for Purposes of 

Distribution (“Motion to Consolidate” or “Motion”), with a hearing date of April 4, 

2019 at 1:30 p.m.; 

WHEREAS, pursuant to the Civil Local Rules, the deadline to file an 

opposition to the Motion to Consolidate is currently March 14, 2019; 

WHEREAS, pursuant to the Civil Local Rules, the deadline to file a reply to 

any opposition to the Motion to Consolidate is currently March 21, 2019; 

WHEREAS, in the Motion to Consolidate, which is accompanied by two 

declarations and includes a detailed forensic accounting analysis, the Receiver seeks 

relief from the Court in the form of an Order consolidating the Receivership Entities 

into a single pool for distribution to EB-5 investors (such as CallSocket, L.P. 

Investors) and creditors; 

WHEREAS, such distribution as proposed by the Receiver may result in 

significant financial and immigration consequences for CallSocket, L.P. Investors; 

WHEREAS, CallSocket, L.P. Investors and their counsel have been diligently 

reviewing the Motion and the forensic accounting analysis contained therein, and 

have been consulting immigration counsel in order to fully understand the 

ramifications of the relief sought in the Motion; 

WHEREAS, given the significant financial and immigration consequences 

that may result from the Court granting the Motion to Consolidate, and taking into 

consideration the difficulty of coordinating with multiple individuals including the 

CallSocket, L.P. Investors themselves, immigration counsel, and accounting 
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BOIES SCHILLER FLEXNER LLP 

 -2- Case No. 17-CV-00223-RS

STIPULATION TO CONTINUE HEARING DATE 

AND ASSOCIATED BRIEFING DEADLINES OF MOTION TO CONSOLIDATE

professionals, CallSocket, L.P. Investors require additional time in order to respond 

to the Motion; 

WHEREAS, the Parties agree that it will serve the interests of fairness and 

judicial economy to continue the hearing date of the Motion to Consolidate to May 

2, 2019, as well as the associated opposition and reply deadlines so that CallSocket, 

L.P. Investors may have adequate time to analyze and respond to the Motion; 

WHEREAS Plaintiff Securities and Exchange Commission has indicated they 

have no objection to the extension of time; and 

WHEREAS, the Parties have not previously filed any request or stipulation 

for extension of time with respect to the Motion to Consolidate. 

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BOIES SCHILLER FLEXNER LLP 

 -3- Case No. 17-CV-00223-RS

STIPULATION TO CONTINUE HEARING DATE 

AND ASSOCIATED BRIEFING DEADLINES OF MOTION TO CONSOLIDATE

THEREFORE, subject to the approval of the Court, the Parties hereby 

stipulate to the entry of and request that the Court enter the following order: 

The hearing on Receiver Susan L. Uecker’s Motion to Consolidate will be 

continued from April 4, 2019 to May 2, 2019 at 1:30 p.m. 

The deadline for CallSocket, L.P. Investors to file any opposition, objections, 

or response to the Motion to Consolidate will be extended from March 14, 2019 to 

April 4, 2019. Such extension shall be for the benefit of the CallSocket, L.P. 

Investors only, and not for any other party. 

The deadline for Receiver Susan L. Uecker to file any reply to the CallSocket, 

L.P. Investors’ response shall be on April 11, 2019. 

Pursuant to Civil Local Rules 6-2 and 7-12, IT IS SO STIPULATED. 

DATED: March 14, 2019 BOIES SCHILLER FLEXNER LLP 

 MICHAEL V SCHAFLER 

LENNETTE W. LEE 

By /s/ Michael V Schafler 

 MICHAEL V SCHAFLER 

Attorneys for Interested Parties 

Li Feng, Ma Xiao, Guo Wenjing, Yuan Zhilin, 

Ma Songjun, Lu Chuan, Ma Wenli, Liu Qi, Li 

Hongmei, Wei Jianjun, and Fan Shuyi 
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BOIES SCHILLER FLEXNER LLP 

 -4- Case No. 17-CV-00223-RS

STIPULATION TO CONTINUE HEARING DATE 

AND ASSOCIATED BRIEFING DEADLINES OF MOTION TO CONSOLIDATE

DATED: March 14, 2019 JEFFER MANGELS BUTLER & 

MITCHELL LLP 

 BENNETT G. YOUNG 

JOSEPH N. DEMKO 

By /s/ Bennett G. Young 

 BENNETT G. YOUNG 

Special Counsel for Receiver SUSAN L. 

UECKER 

ATTESTATION PURSUANT TO LOCAL RULE 5-1 

Pursuant to Local Rule 5-1 of the Northern District of California, I attest that 

concurrence in the filing of this document has been obtained from each of the other 

signatories to this document. 

DATED: March 14, 2019 BOIES SCHILLER FLEXNER LLP 

 MICHAEL V SCHAFLER 

LENNETTE W. LEE 

By /s/ Michael V Schafler 

 MICHAEL V SCHAFLER 

Attorneys for Interested Parties 

EB-5 Investors in CallSocket, L.P. 
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BOIES SCHILLER FLEXNER LLP 

 -1- Case No. 17-CV-00223-RS

DECLARATION OF MICHAEL V SCHAFLER

DECLARATION OF MICHAEL V SCHAFLER 

I, MICHAEL V SCHAFLER, declare and state as follows: 

1. I am an attorney admitted to practice in the State of California and a 

member of the bar of this Court. I am an attorney at Boies Schiller Flexner LLP, 

counsel for Interested Parties Li Feng, Ma Xiao, Guo Wenjing, Yuan Zhilin, Ma 

Songjun, Lu Chuan, Ma Wenli, Liu Qi, Li Hongmei, Wei Jianjun, and Fan Shuyi 

(collectively, “CallSocket, L.P. Investors”). I submit this declaration in support of 

the Stipulation to Continue Hearing Date of Motion for Order Consolidating the 

Receivership Entities for Purposes of Distribution (“Motion to Consolidate” or 

“Motion”) filed by Receiver Susan L. Uecker. I have personal knowledge of the 

facts stated herein, and could and would testify competently thereto if called as a 

witness in this matter. 

2. On February 28, 2019, I was served electronically via ECF with 

Receiver Susan L. Uecker’s Motion to Consolidate. 

3. Since my receipt of the Motion, I have been working with my clients 

and immigration counsel in order to fully understand the potential immigration 

consequences of the relief sought by the Motion. 

4. Due to the summary of the complex forensic accounting analysis 

contained in the Motion and moving papers, I also anticipate that it will take some 

time to analyze the conclusions of the forensic accounting and the financial 

implications of the relief sought by the Motion. I anticipate that it may be necessary 

for my clients to request the underlying accounting data and to independently 

consult accounting professionals to assess the conclusions of the Receiver’s 

accountants and the financial impacts that may result if the financial analysis in the 

Motion is endorsed and adopted. 

5. On Monday, March 11, 2019, I emailed Ms. Uecker to request 

additional time to consider whether my clients need to respond to the Motion and, if 

so, to prepare a response. I have since been in contact via email with Ben Young, 
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BOIES SCHILLER FLEXNER LLP 

 -2- Case No. 17-CV-00223-RS

DECLARATION OF MICHAEL V SCHAFLER

Ms. Uecker’s counsel specially appearing for the Motion, to discuss a possible 

extension of both the hearing date on the Motion and my clients’ time to respond. 

6. On March 13, 2019, Mr. Young indicated via email that Ms. Uecker 

would agree to: (a) continuing the hearing date on the Motion to May 2, 2019 at 

1:30 p.m.; (b) extending CallSocket, L.P. Investors’ deadline to respond to the 

Motion by three weeks, such that any opposition, objection, or response from 

CallSocket, L.P. Investors will be due by no later than April 4, 2019; and (c) 

extending Ms. Uecker’s reply to any response by CallSocket, L.P. Investors to one 

week thereafter, by April 11, 2019. Mr. Young further represented that Plaintiff 

Securities and Exchange Commission has no objection to the extension of these 

deadlines. 

7. To my knowledge, this is the first request or stipulation for extension of 

time with respect to the Motion to Consolidate. 

I declare under penalty of perjury under the laws of the United States of 

America that the foregoing is true and correct. 

Executed March 14, 2019, at Los Angeles, California. 

 /s/ Michael V Schafler

MICHAEL V SCHAFLER 
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BOIES SCHILLER FLEXNER LLP 

 -1- Case No. 17-CV-00223-RS

[PROPOSED] ORDER

[PROPOSED] ORDER 

PURSUANT TO STIPULATION, IT IS SO ORDERED. 

The hearing on Receiver Susan L. Uecker’s Motion for Order Consolidating 

the Receivership Entities for Purposes of Distribution (“Motion”) will be continued 

from April 4, 2019 to May 2, 2019 at 1:30 p.m. 

The deadline for Interested Parties Li Feng, Ma Xiao, Guo Wenjing, Yuan 

Zhilin, Ma Songjun, Lu Chuan, Ma Wenli, Liu Qi, Li Hongmei, Wei Jianjun, and 

Fan Shuyi (collectively, “CallSocket, L.P. Investors”) to oppose, object or otherwise 

respond to the Motion is extended from March 14, 2019 to April 4, 2019. 

The deadline for Receiver Susan L. Uecker to file any reply to the CallSocket, 

L.P. Investors’ response shall be on April 11, 2019. 

DATED: ______________ By

 The Honorable Richard Seeborg 

3/15/19