STIPULATION AND [PROPOSED] ORDER EXTENDING THE TIME FOR XEROX CONSULTANT COMPANY, INC. TO RESPOND TO COUNTERCLAIMS OF MARINGENERAL HOSPITAL CORPORATION

EDWARD M. CHEN, District Judge.

Pursuant to Local Rules 6-2 and 7-12 and this Court's Civil Standing Order, Plaintiff and Counter-Defendant Xerox Consultant Company, Inc. ("Xerox") and Defendant and Counter-Claimant Marin General Hospital Corporation ("MGHC")(collectively, the "Parties"), by and through their counsel stipulate as follows:

WHEREAS, Xerox filed its Complaint in this matter on September 21, 2012 (Dkt. # 1);

WHEREAS, the Parties stipulated on October 19, 2012 that MGHC may respond to the Complaint on or before November 5, 2012 (Dkt. # 8);

WHEREAS, the Parties further stipulated on November 5, 2012 to extend the deadline for MGHC's response to the Complaint to November 20, 2012 (Dkt. # 10);

WHEREAS, MGHC filed its Answer to Xerox's Complaint and Counterclaims on November 21, 2012 (Dkt. # 11);

WHEREAS, Xerox's response to MGHC's Counterclaims is due on December 12, 2012;

WHEREAS, on December 10, 2012 the Parties agreed to extend the deadline for Xerox's response to MGHC's Counterclaims in order to provide additional time for them to meet and confer regarding the content of MGHC's Counterclaims;

WHEREAS, this requested extension will not materially impact the existing schedule for the case.

NOW THEREFORE, the Parties through their respective counsel stipulate that Xerox's response to MGHC's Counterclaims shall be due on or before December 20, 2012.

IT IS SO ORDERED.

DECLARATION OF PHILIP F. ATKINS-PATTENSON

I, Philip F. Atkins-Pattenson, declare as follows:

1. I am an attorney duly admitted to practice before this Court. I am a partner with Sheppard, Mullin, Richter & Hampton LLP, attorneys of record for Plaintiff and Counter-Defendant XEROX CONSULTANT COMPANY, INC. ("Xerox").

2. If called as a witness, I could and would competently testify to the matters set forth in this declaration.

3. Xerox and Defendant and Counter-claimant Marin General Hospital Corporation ("MGHC" and collectively, the "Parties") stipulated on October 19, 2012 that MGHC may respond to Xerox's Complaint on or before November 5, 2012.

4. The Parties further stipulated on November 5, 2012 to extend the deadline for MGHC's response to the Complaint to November 20, 2012.

5. MGHC filed its Answer to Xerox's Complaint and Counterclaims on November 20, 2012.

6. Xerox's response to MGHC's Counterclaims is due on December 12, 2012.

7. On December, 10, 2012, MGHC's counsel, Mr. Straus, and I agreed to extend the deadline for Xerox's response to the Counterclaims, subject to this Court's approval, in order to provide additional time for the Parties to meet and confer regarding the content of MGHC's Counterclaims.

8. This requested extension will not materially impact the existing schedule for the case.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.