[PROPOSED] ORDER AND STIPULATION GRANTING THE INDEPENDENT MONITOR AND HIS COUNSEL'S MOTION FOR THE PAYMENT OF FEES

EDWARD M. CHEN, District Judge.

The parties, U.S. Securities & Exchange Commission, and defendants Saddle River Advisers, LLC ("Saddle River") and SRA Management Associates, LLC ("SRA Management"), hereby stipulate and agree to the entry of an order as follows:

1.) The Independent Monitor in this matter, Michael A. Maidy, and his special counsel John W. Cotton, have each submitted their bills for services and expenses for the period of March 25 to April 30, 2016, in a Motion to the Court dated May 11, 2016 (Docket # 78).

2.) Pursuant to the Court's TRO order dated March 25, 2016 (Docket # 36), defendants Saddle River and SRA Management shall be responsible for the payment of the reasonable costs, fees and expenses of the Independent Monitor and any attorney hired by him

3.) The parties to these fee applications, plaintiff U.S. Securities and Exchange Commission and defendants Saddle River and SRA Management, have reviewed the specific bills referred to above in Paragraph 1. Saddle River and SRA Management hereby give their approval to payment of the specific bills, while the U.S. Securities and Exchange Commission does not oppose the specific bills or their payment.

4.) The costs, fees and expenses approved by the parties herein shall be paid as soon as is practicable by defendants Saddle River and SRA Management.

SO STIPULATED.

Pursuant to Civil L.R. 5.1, I hereby attest that I have on file all holographic signatures corresponding to any signatures indicated by a conformed signature (/S/) within this e-filed document.

IT IS SO ORDERED.