STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE AMENDED COMPLAINT (FOURTH REQUEST)

CARL W. HOFFMAN, Magistrate Judge.

Plaintiffs Remark Holdings, Inc. and Kankan Limited, and Defendant Adam Roseman hereby stipulate and agree that the deadline to file an Amended Complaint should be extended from May 3, 2019, until May 24, 2019. In support of this stipulation, the parties to this stipulation state as follows:

1. On March 26, 2019, the Court issued a Decision and Order granting in part and denying in part Roseman's motion to dismiss the Complaint, and granting Plaintiffs leave to file an Amended Complaint on or before April 9, 2019 (ECF No. 66). All parties in this action previously requested, and were granted, an extension of time to file an Amended Complaint until April 19, 2019. The Court granted a second extension until April 26, 2019, and the Court granted a third extension until May 3, 2019.

2. Plaintiff and Defendant Roseman have reached a settlement in principle and Plaintiffs seek additional time to finalize and execute a written settlement agreement, and make this extension request in an effort to preserve judicial and party resources.

3. Defendant Roseman consents to this request.

4. Defendant China Branding Group Limited (in Official Liquidation) acting through its Joint Official Liquidators, Hugh Dickson of Grant Thornton Specialist Services, and David Bennett of Grand Thornton Recovery and Reorganization Ltd. (the "Cayman Defendants") do not take a position on this application, but respectfully reiterate the request made in their prior filing (ECF No. 67 at 1, lines 26-27) that the Court rule upon their pending motion to dismiss. (ECF No. 40).

5. Plaintiffs object to the request of the Cayman Defendants on the basis that it is procedurally irrelevant to the request for an extension and mooted by the Stipulation for Settlement and Motion to Enforce. (See ECF No. 63).

6. This is the fourth request to extend the time for Plaintiffs to file an Amended Complaint.

IT IS SO ORDERED: