STIPULATION BY ALL PARTIES TO:

(1) TO EXTEND TIME IN WHICH TO RESPOND TO PLAINTIFF'S COMPLAINT PURSUANT TO LOCAL RULE 144(a)

(2) STIPULATION TO TRANSFER CASE TO UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION PURSUANT TO 28 U.S.C. § 1404(b) AND LOCAL RULE 120(f)

LAWRENCE J. O'NEILL, District Judge.

TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA, AND TO ALL PARTIES THROUGH THEIR COUNSEL OF RECORD HEREIN:

Plaintiff AMERICAN PAYROLL OUTSOURCING, INC. DBA APO STAFFING, INC. ("APO") and Defendants SOUTHEAST PERSONNEL LEASING, INC. ("SPLI") and PACKARD CLAIMS ADMINISTRATION, INC. ("Packard") (collectively the "Parties"), by and through their respective counsel of record, hereby agree and stipulate to the following:

1. On February 16, 2017, this case was timely and properly removed to this Court by Defendants based on diversity of citizenship jurisdiction (28 U.S.C. §§ 1332 and 1441(b).)

2. A response to the Complaint is due to be filed no later than seven days after removal, or February 23, 2017.

3. The Parties have met and conferred and agree the appropriate venue for this matter, based upon a forum selection provision in the governing contract, the interests of justice, and the convenience of the Parties, is the United States District Court for the Central District of California, Southern Division.

4. In accordance with 28 U.S.C. § 1404(b) and Local Rule 120(f) the Parties hereby agree and stipulate to transfer this case to the United States District Court for the Central District of California, Southern Division.

5. Given that a responsive pleading is due on or before February 23, 2017, the Parties also agree and stipulate that Defendants be provided an initial extension of time of no more than 28 days to respond to the Complaint pursuant to Local Rule 144(a). Defendants' responsive pleadings will therefore be due no later than March 23, 2017.

6. This one-time extension will allow sufficient time for the case to be transferred to the Central District, and will also allow the Parties an opportunity to attempt to resolve this matter prior to the time a responsive pleading is due.

7. Good cause exists both as to the transfer of this matter, as well as the extension of time for Defendants to respond to the Complaint as indicated above.

IT IS SO STIPULATED.

GOOD CAUSE APPEARING, this case is hereby transferred to the United States District Court for the Central District of California, Southern Division. Defendants have up to and including March 23, 2017 to respond to the Complaint.

IT IS SO ORDERED.