STIPULATION AND [ ] SCHEDULING ORDER

RONALD M. WHYTE, District Judge.

WHEREAS, on June 28, 2011, the Court issued an Order Granting in Part and Denying in Part Lisa C. Berry's Administrative Motion to File Under Seal [Re Docket No. 240] (Dkt. 253), which required persons who have claimed confidentiality over any document attached to Ms. Berry's motion for summary judgment to produce an itemized description of the confidentiality basis for each document and a proposed order narrowly tailored to the confidential information by August 29, 2011;

WHEREAS, on July 27, 2011, the Court issued an Order Granting Securities and Exchange Commission's Administrative Motion to Provisionally Seal Filings in Opposition to Motion for Partial Summary Judgment (Dkt. 274) that ordered the Commission maintain certain documents filed under seal until further notice from the Court in accordance with Dkt. No. 253;

WHEREAS, on July 27, 2011, the Court issued an Order Granting Lisa C. Berry's Administrative Motion to File Under Seal Pursuant to Stipulated Protective Orders, Civil L.R. 79-5 and General Order 62 (Dkt. 275) that ordered that certain documents be filed under seal until further notice from the Court;

WHEREAS on August 10, 2011, the Court issued an Order Granting Lisa C. Berry's Administrative Motion to File Under Seal Pursuant to Stipulated Protective Orders, Civil L.R. 79-5 and General Order 62 (Dkt. 290) that certain documents be maintained under seal until further notice from the Court in accordance with Dkt. No. 253;

WHEREAS, non-parties KLA-TENCOR CORPORATION ("KLA"), JUNIPER NETWORKS, INC. ("Juniper") and ERNST & YOUNG LLP ("E&Y") designated certain documents and deposition excerpts as confidential that were to be maintained under seal pursuant to the Court's orders (Dkt. Nos. 253, 274, 275, 290), and were to produce an itemized description of the confidentiality basis for each of those documents and a proposed order narrowly tailored to the confidential information by August 29, 2011;

WHEREAS, on August 19, 2011, Plaintiff Securities and Exchange Commission ("SEC") and Defendant Lisa C. Berry ("Ms. Berry") (collectively, the "Parties") filed a Stipulation and Proposed Scheduling Order (Dkt. 302) resetting the dates for trial to commence, the pretrial conference, and the hearing on pending motions for partial summary judgment;

WHEREAS, on August 23, 2011, the Court approved the Stipulation and Scheduling Order (Dkt. 303) resetting the dates for trial to commence to January 9, 2010, the pretrial conference to December 15, 2011, and the hearing on pending motions for partial summary judgment to November 18, 2011;

WHEREAS the undersigned parties and non-parties agree that a comparable extension of the date by which persons who have claimed confidentiality over any documents or deposition excerpts that are currently maintained under seal pursuant to the Court's orders is desirable to avoid undue burden and expense for the Court, parties and non-parties;

IT IS HEREBY STIPULATED AND AGREED, by and between undersigned counsel that:

1. The date for non-parties KLA, Juniper and E&Y to produce an itemized description of the confidentiality basis for documents and deposition excerpts currently maintained under seal pursuant to the Court's orders and to submit a proposed order narrowly tailored to the confidential information is extended to November 21, 2011, which is a comparable date to the schedule currently in place for making this submission.

IT IS SO STIPULATED.

Pursuant to General Order No. 45, Electronic Case Filing § X-B, the filer attests that concurrence in the filing of this document has been obtained from each of the above signatories.

ORDER

Pursuant to the stipulation of the parties, and for good cause shown, the Court resets the date by which any person who has claimed confidentiality over any documents attached to the parties' motions for summary judgment evidentiary objections must produce an itemized description of the confidentiality basis for each document and a proposed order narrowly tailored to the confidential information to November 21, 2011.