HRUSA's memo in opposition to Yahoo's attempt to bifurcate the proceedings and to delay pre-trial discovery. Yahoo had asked the court to hold an early case management conference, which would have required the court to address certain issues prematurely, without all of the facts before it, and before discovery could be conducted on these issues. Keywords: Yahoo, china, internet, wang xiaoning, yu ling, shi tao, torture, atca, tvpa, free speech