STIPULATION AND PROPOSED ORDER SUSPENDING DEADLINES AS TO DEFENDANT AKBARI

HAYWOOD S. GILLIAM, Jr., District Judge.

Plaintiff Securities and Exchange Commission ("Commission" or "SEC") and defendant Ammar Akbari hereby submit the following Stipulation and Proposed Order, and request that the Court suspend upcoming deadlines as to Akbari, as follows:

WHEREAS counsel for the Commission, and counsel for Defendant Akbari have been working for months to determine whether a settlement of the Commission's case as to Akbari could be reached;

WHEREAS the Commission's counsel and Akbari's counsel have arrived at a settlement in principle that the Commission's counsel expects to recommend to the Commission itself for consideration and approval or disapproval;

WHEREAS the process for obtaining Commission consideration and approval requires a formal presentation of an offer to the commissioners who sit in Washington, D.C., and given the press of their business, the process typically takes approximately eight weeks to complete;

WHEREAS a Settlement Conference before Magistrate Judge Ryu is scheduled for March 13, 2015, at which the parties and their counsel are ordered to attend;

WHEREAS defendant Akbari will lose much of the value of making a settlement offer early in this litigation (before the Settlement Conference and before the resumption of discovery and before his Answer is due) if he is nevertheless required to attend such events at substantial cost to him;

ACCORDINGLY, it is HEREBY STIPULATED by and between the undersigned parties that Defendant Akbari should be relieved of the obligation to meet deadlines in this case for a period of 90 days from the date of the filing of this Stipulation. If, within the 90 days, the Commission has considered and either approved or rejected the settlement offer, the SEC and Defendant Akbari will so inform the Court immediately.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Good cause appearing from the above Stipulation, the requested 90-day suspension of all deadlines as to Defendant Ammar Akbari is hereby GRANTED. IT IS HEREBY ORDERED THAT the Plaintiff Securities and Exchange Commission and Defendant Ammar Akbari will report to the Court no later than 90 days from the date of entry of this Order to inform the Court whether a settlement between them has been approved by both parties.

IT IS SO ORDERED.