STIPULATED REQUEST AND [PROPOSED] ORDER EXTENDING TIME TO FILE AMENDED ANSWER

EDWARD M. CHEN, District Judge.

Pursuant to United States District Court, Northern District of California Local Rules 6-1 and 6-2, and as supported by the Declaration of Reed E. Harvey filed herewith, ANDERSEN TAX LLC, a Delaware limited liability company ("Andersen Tax LLC") and ARTHUR ANDERSEN & CO., SAS, a Societe par Actions Simplifiee ("Arthur Andersen") through their undersigned counsel, hereby stipulate and respectfully request an extension of time for Arthur Andersen to file an amended answer in this action by 20 days.

WHEREAS, by order dated June 16, 2017, Judge Edward M. Chen ordered Arthur Andersen to obtain counsel and file an amended Answer by July 31, 2017 pursuant to an Order Granting in Part and Denying in Part Plaintiff's Motion to Strike Defendant's Answer;

WHEREAS, Arthur Andersen retained its counsel, Reed E. Harvey and Frederick K. Koenen of SCHINNER & SHAIN, LLP, 96 Jessie Street, San Francisco, CA 94105 on July 28, 2017;

WHEREAS, the Parties are in agreement that the Court should enlarge time for Arthur Andersen to file an amended answer to Plaintiff's complaint.

NOW, THEREFORE, pursuant to Local Rule 6-2, the parties through their respective counsels stipulate to the Court's entry of an Order granting Arthur Andersen an extension of time to and including on August 17, 2017 in which to file an amended answer to the complaint filed in this action.

IT IS SO STIPULATED,

ATTESTATION FOR SIGNATURE

Pursuant to Civil L.R. 5-1(i)(3) regarding signatures, I attest under penalty of perjury that concurrence in the filing of this document has been obtained from the other signatories.

[PROPOSED] ORDER

Having considered the parties' Stipulated Request for an Order Changing Time, and for good cause shown,

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED, that Arthur Andersen should file its Amended Answer by August 17, 2017.

DECLARATION OF REED E. HARVEY IN SUPPORT OF STIPULATED REQUEST AND [PROPOSED] ORDER EXTENDING TIME TO FILE AMENDED ANSWER

I, Reed E. Harvey, declare:

1. I am an attorney duly licensed to practice law in the State of California and admitted to practice before this Court. I am an attorney with Schinner & Shain, LLP, which is counsel for defendant ARTHUR ANDERSEN & CO., SAS, a Societe par Actions Simplifiee ("Arthur Andersen"). I have personal knowledge of each fact stated in this declaration, except for ones stated on information and belief, and would offer competent testimony as to the matters herein if called to do so.

2. Plaintiff ANDERSEN TAX LLC, a Delaware limited liability company ("Andersen Tax LLC") and defendant Arthur Anderson through their respective counsel of record are stipulating to the entry of an order pursuant to which request is made that the Court extend the time in which Arthur Anderson may file an Amended Answer in this case from July 31, 2017 to August 17, 2017.

3. The request is made for good cause in that Arthur Anderson engaged Schinner & Shain, LLP to represent them in this action in the afternoon of July 28, 2017. We are acting diligently in this matter, however, we will be unable to file an amended answer by July 31, 2017 and request that the stipulated Order be entered by the Court. Our client is a French entity and our client's representatives are all located in France. As a result of our retention and the immediate need to obtain the requested extension we not have yet had time to discuss the substance of this litigation with our client or conduct a thorough review of the complaint, its allegations and legal theories.

4. In reviewing the docket for this case, it appears that there were two previous modification of time in this case:

5. Arthur Andersen believes that it will be able to comply with these dates and that there should be no need for an additional extension of time.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 31st day of July, 2017, at San Francisco, California.