STIPULATION AND [PROPOSED] ORDER AMENDING ORDER GRANTING PRELIMINARY INJUNCTION

RICHARD SEEBORG, District Judge.

STIPULATION AND [PROPOSED] ORDER

Plaintiff Securities and Exchange Commission, Defendants eAdGear, Inc., eAdGear Holdings Limited, Charles Wang, Qian Cathy Zhang, Francis Yuen, and Laurata Chan (collectively the "Parties"), by and through their counsel of record, state as follows:

WHEREAS, Plaintiff filed this action on September 24, 2014 [Dkt. No. 1], seeking a temporary restraining order and a Preliminary Injunction that would, among other things, enjoin Defendants from engaging in specified conduct, freeze the assets of Defendants and specified assets of the Relief Defendant, and require repatriation of assets [Dkt. No. 3];

WHEREAS, on December 8, 2014, this Court entered the Order Granting Preliminary Injunction [Dkt. No. 58];

WHEREAS, further on December 8, 2014, this Court entered the Amended Order Granting Preliminary Injunction (the "Amended Preliminary Injunction Order") [Dkt. No. 60], in which the Court granted defendants, Francis Yuen and Laurata Chan, monthly living expenses and periodical tax payments from their Wells Fargo Bank account number XXX-XXX8183;

WHEREAS, subsequently, Wells Fargo Bank has encountered problems in freezing and unfreezing the XXX-XXX8183 bank account; and

WHEREAS, counsel for defendants Francis Yuen and Laurata Chan has met and conferred with counsel for Plaintiff Securities and Exchange Commission and counsel for Wells Fargo Bank;

NOW THEREFORE, the Parties, by and through their counsel of record, stipulate to further amend the Amended Preliminary Injunction Order as following:

The Amended Preliminary Injunction Order shall be further amended as the attached [PROPOSED] SECOND AMENDED ORDER GRANTING PRELIMINARY INJUNCTION.

ORDER

PURSUANT TO THE PARTIES' STIPULATION, IT IS SO ORDERED.