STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO THE INITIAL COMPLAINT AND POSTPONE THE INITIAL CASE MANAGEMENT CONFERENCE

RICHARD SEEBORG, District Judge.

WHEREAS, the Securities and Exchange Commission ("SEC") filed the above-captioned action on September 28, 2011 against Defendants Kurt S. Hovan, Lisa B. Hovan, Edward J. Hovan, and Hovan Capital Management, LLC (collectively, "Defendants");

WHEREAS, the parties filed a stipulation on November 23, 2011 to extend Defendants' time to respond to the Complaint until January 3, 2011 (Docket No.18);

WHEREAS, the Defendants believe that an additional extension is appropriate and necessary to coordinate this action with related criminal proceedings, and the SEC does not object to such an extension. The parties have met and conferred and agree to extend the time for Defendants to respond to the Complaint to February 3, 2012 and set the case management conference on February 16, 2012 after Defendants have filed their response or as soon thereafter as available;

NOW, THEREFORE, the undersigned parties hereby stipulate and agree, and respectfully request that the Court enter an Order as follows:

1. Defendants shall file their response to the Complaint on or before February 3, 2012;

2. The case management conference shall be moved to February 16, 2012, or as soon thereafter as available.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Pursuant to the Stipulation, IT IS SO ORDERED.

ATTESTATION PURSUANT TO GENERAL ORDER 45

I, Emily H. Wood, attest that concurrence in the filing of this document has been obtained from any signatories indicated by a conformed signature (/s/) within this electronically-filed document. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Executed this 22nd day of December, 2011, at San Francisco, California