STIPULATION SETTING BRIEFING SCHEDULE AND HEARING DATE OF MOTION TO WITHDRAW THE REFERENCE, AND ORDER [Local Rule 7-12]

Bankruptcy Case No. 17-40327 RLE

Adversary Proceeding No. 17-04020 RLE

HAYWOOD S. GILLIAM, JR., District Judge.

This Stipulation is entered into by and between Plaintiff Marlene G. Weinstein, Chapter 7 Trustee of the estate of Independent Adoption Center, by and through her counsel Jeffrey L. Fillerup of Rincon Law LLP, and Defendants Greg Kuhl, Susan Sparling, Alex Kaplan, Nancy Worrell, Daniel Ward, William Kinnane, and Christine Zwerling (collectively "Director Defendants"), by and through their counsel Jason W. Mauck of Ericksen Arbuthnot, as follows:

WHEREAS, on February 3, 2017, Independent Adoption Center (the "Debtor") filed a Chapter 7 bankruptcy petition, Bankruptcy Case No. 17-40327 RLE;

WHEREAS, Plaintiff Marlene G. Weinstein was appointed as the Chapter 7 Trustee of the Debtor's estate (the "Trustee");

WHEREAS, on March 21, 2017, the Trustee filed an adversary proceeding, A.P. No. 17-4020 RLE (the "Adversary Proceeding"), against certain former members of the Debtor's Board of Directors, referred to as the Director Defendants, and a former officer of the Debtor, Marcia Hodges;

WHEREAS, the Director Defendants filed a motion to withdraw the reference of the Adversary Proceeding from the Bankruptcy Court to this Court, and such motion was assigned Case No. 18-cv-01545-HSG;

WHEREAS, Marcia Hodges filed a motion to withdraw the reference of the Adversary Proceeding from the Bankruptcy Court to this Court, and such motion was assigned Case No. 18-cv-01351-HSG;

WHEREAS, the Trustee plans to oppose the two motions to withdraw the reference;

WHEREAS, the two motions to withdraw the reference relate to the same case in the Bankruptcy Court (A.P. No. 17-04020-RLE), so the parties believe that it is in the interest of judicial economy to have the same briefing schedule and hearing date for both motions to withdraw the reference; and

WHEREAS, the parties enter into this Stipulation pursuant to Local Rule 7-12 and seek an order approving the common dates for the further briefing of the motions and the setting of the hearing date for the two motions at the same time, as follows:

1. The hearing date of the Director Defendants' motion to withdraw the reference (Case No. 18-cv-01545-HSG) will be set for July 11, 2018 at 2:00 p.m. in Courtroom 2, 4th Floor, 1301 Clay Street, Oakland, California.

2. The date for the Trustee's filing of an opposition to the Director Defendants' motion to withdraw the reference is set for May 29, 2018.

3. The reply brief in support of the Director Defendants' motion to withdraw the reference is set for June 12, 2018.

4. Any prior hearing dates and briefing schedules are taken off calendar.

IT IS SO STIPULATED.

ORDER

Based on the foregoing Stipulation, and for good cause appearing, IT IS HEREBY ORDERED that the foregoing stipulation is approved and is ordered.