STIPULATION EXTENDING TRIAL AND OTHER DATES AND PROPOSED ORDER THEREON

RONALD M. WHYTE, District Judge.

TO THE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

Plaintiff Universal Green Solutions, LLC ("Universal"), Defendant/Third-Party Plaintiff VII Pac Shores Investors, LLC ("Pac Shores") and Third-Party Defendant Cushman & Wakefield of California, Inc. ("Cushman & Wakefield"), through their attorneys, stipulate and agree as follows:

1. Universal filed this action against Pac Shores and Does 1 to 20 on November 1, 2012;

2. At that time, the matter was assigned to Magistrate Judge Paul S. Grewal and an Order Setting Initial Case Management Conference and ADR Deadlines was issued;

3. On January 30, 2013, all matters before Magistrate Judge Grewal were vacated and this action was reassigned to the Honorable Ronald M. Whyte;

4. On April 5, 2013, the Court held a Case Management Conference and set the following dates:

5. On August 23, 2013, Pac Shores filed and served a Motion for Leave to File Third-Party Complaint, which was granted by the Court on September 18,2013;

6. On September 12, 2013, the Court continued the Fact and Expert Discovery Cut-Off to November 15, 2013 and the Deadline for Hearing on Dispositive Motions to December 20, 2013 at 9:00 a.m.;

7. Pac Shores filed and served its unverified Third-Party Complaint For Express Contractual Indemnity And Declaratory Relief on Cushman & Wakefield on October 1, 2013;

8. Cushman & Wakefield was not previously named as a party in this action;

9. Cushman & Wakefield filed and served its Answer To VII Pac Shores Investors, LLC's Unverified Third-Party Complaint For Express Contractual Indemnity And Declaratory Relief; And Demand For Jury Trial on October 21, 2013;

10. Per the stipulation of the parties, Cushman & Wakefield's deadline to serve its Initial Disclosure Statement in this action is November 14, 2013;

11. Having just recently appeared in this action, Cushman & Wakefield has not had an opportunity to investigate or conduct discovery regarding the basis of Pac Shores' allegations and/or the incident(s) giving rise to this action;

12. Having just recently appeared in this action, Cushman & Wakefield will be unable to complete fact and expert discovery prior to the November 15, 2013 cut-off, file dispositive motions by the December 20,2013 deadline, and prepare for the trial set for January 21, 2014;

13. Specifically, Cushman & Wakefield needs an opportunity to conduct written discovery and depose the other parties to this action, and depending on the outcome of its initial investigation and discovery, may need to issue subpoenas and notice depositions of third party witnesses;

14. Cushman & Wakefield needs an opportunity to complete the aforementioned discovery and file dispositive motions in advance of trial;

15. If it is otherwise unable to resolve this matter through law & motion practice or ADR, Cushman & Wakefield needs an opportunity to properly prepare for trial;

16. Universal and Pac Shores estimate that in addition to written discovery, they have approximately ten (10) depositions to complete;

17. To enable the parties to complete the aforementioned objectives and in consideration of their counsels' respective trial conflicts, they agree that the trial date should be continued to June 10, 2014 or thereafter;

18. The parties agree that all discovery and law & motion cut-offs and deadlines should be vacated and that new discovery and law & motion cut-offs and deadlines should be set in accordance with the new trial date;

19. The parties agree there is good cause to continue the January 21, 2014 trial date and corresponding discovery and law & motion cut-offs and deadlines;

20. The parties agree that the brief extension will not cause undue delay;

21. A trial date in June 2014 would be less than eight (8) months from the date Cushman & Wakefield appeared in this action;

22. The parties agree that the brief extension will not prejudice Universal or Pac Shores; and

23. The parties agree that Cushman & Wakefield will be unduly prejudiced if the Court does not grant the brief extension requested by the parties;

THEREFORE, IT IS HEREBY STIPULATED and agreed by and between Universal, Pac Shores and Cushman & Wakefield, by and through their respective attorneys of record, that the January 21, 2014 trial date shall be extended to June 10, 2014 or a date thereafter that comports with the Court's schedule.

IT IS FURTHER STIPULATED and agreed by and between the parties that the Pretrial Conference scheduled for January 9, 2014 shall be extended to May 29* 2014 or a date thereafter that comports with the Court's schedule.

IT IS FURTHER STIPULATED and agreed by and between the parties that the December 20, 2013 Deadline for Hearing on Dispositive Motions shall be extended to May 16, 2014 or a date thereafter that comports with the Court's schedule,

IT IS FURTHER STIPULATED and agreed by and between the parties that the Fact and Expert Discovery Cut-Off of November 15, 2013 shall be extended to Aprilll, 2014 or a date thereafter that comports with the Court's schedule.

IT IS SO STIPULATED.

[PRPPOSED ORDER

GOOD CAUSE APPEARING THEREFORE, and the parties having stipulated thereto,

IT IS HEREBY ORDERED as follows:

1. The trial scheduled for January 21, 2014 shall be extended to June 16, 2014.

2. The Pretrial Conference scheduled for January 9, 2014 shall be extended to June 5, 2014.

3. The Deadline for Hearing on Dispositive Motions scheduled for December 20, 2013 shall be extended to May 2, 2014.

4. The Fact and Expert Discovery Cut-Off scheduled for November 15, 2013 shall be extended to April 11, 2014.

PURSUANT TO STIPULATION, IT IS SO ORDERED.