STIPULATION AND ORDER TO EXTEND THE DEADLINE TO FILE A RESPONSIVE PLEADING [L.R. 144(a)]

SANDRA M. SNYDER, Magistrate Judge.

Cross-Defendants ROBERT C. BORCHERT, AGNES BORCHERT, RAFAEL ANTONIO FEMATT, and MADISON ONE HOLDINGS, LLC (collectively, "Cross-Defendants"), and Cross-Complainant, STAN BROWN, individually and as a shareholder of GLOBAL TECH SYSTEMS, INC., ("Cross-Complainant"), by and through their respective counsel, hereby agree and stipulate, subject to approval of the Court, to extend the deadline for filing a responsive pleading to Stan Brown's Cross-Complaint from December 28, 2015, up to January 25, 2016, in light of the following:

RECITALS

WHEREAS, Cross-Complainant filed a Cross-Complaint for Damages (the "Cross-Complaint") on November 6, 2015, in United Stated District Court, Eastern District of California, Case No. 1:12-cv-01310.

WHEREAS, a Summons in a Civil Case was issued in the above-referenced action on November 6, 2015 (the "Summons").

WHEREAS, Cross-Defendants were served with a copy of the Cross-Complaint and Summons at various times between November 10, 2015 and November 16, 2015.

WHEREAS, Cross-Defendants retained counsel on November 30, 2015;

WHEREAS, Cross-Defendants were required to file a responsive pleading between December 1, 2015 and December 7, 2015.

WHEREAS, counsel for Cross-Complainant and counsel for Cross-Defendants agreed that in light of the recent engagement of counsel, coupled with counsel having just finished a four-week trial in Merced County and an impending week-long arbitration, Cross-Complainant would extend the time for Cross-Defendants to file a responsive pleading by less than twenty eight (28) days, thereby extending that time for Cross-Defendants to file a responsive pleading to on or before December 28, 2015.

WHEREAS, Cross-Defendants' counsel has been lead counsel on a four-week trial in Merced County and a one-week arbitration in Fresno during the months of November and December. Phase I of the arbitration concluded on Monday, December 15, 2015. With closing briefs due the week of December 22nd for the trial in Merced, coupled with the upcoming holidays, Cross-Defendants' counsel will be not be able to meaningfully come up to speed on the matter in time to draft responsive pleadings by the previously extended filing deadline.

WHEREAS, with the Court's approval, counsel for Cross-Complainant and counsel for Cross-Defendants have agreed to further extend the time for Cross-Defendants to file a responsive pleading by an additional twenty eight (28) days, thereby extending the time for Cross-Defendants to file a responsive pleading to on or before January 25, 2016.

STIPULATION

IT IS HEREBY STIPULATED AND AGREED by and between Cross-Complainant and Cross-Defendants as follows:

1. The time by which Cross-Defendants have to file a responsive pleading is extended to on or before January 25, 2016.

IT IS SO STIPULATED.

ORDER

Pursuant to stipulation and good cause having been show, IT IS SO ORDERED:

1. The time for Cross-Defendants to file an Amended Answer shall be extended to on or before January 25, 2016.

IT IS SO ORDERED.