JOINT STIPULATION AND [PROPOSED] ORDER JOINT STIPULATION REGARDING SPECIALLY APPEARING DEFENDANTS' WAIVER OF THE SERVICE OF SUMMONS AND CORRESPONDING EXTENSION OF TIME TO RESPOND TO COMPLAINT

EDWARD M. CHEN, District Judge.

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

Plaintiff Great Dynasty International Financial Holdings Limited ("Plaintiff"), Specially Appearing Individual Defendants Haiting Li and Zhiyan Li, and Specially Appearing Nominal Defendant Pacific Bepure Industry Inc. (all Defendants referred to as the "Specially Appearing Defendants") (Plaintiff and Specially Appearing Defendants collectively referred to as the "Parties"), through their respective counsel, stipulate, agree, and jointly move the Court as follows:

WHEREAS, Plaintiff filed its Complaint on April 14, 2013 (Dkt. No. 1);

WHEREAS, Plaintiff has been attempting to serve the Summons and Complaint in compliance with the Hague Convention pursuant to Fed. R. Civ. P. 4(f)(1), as set forth in its Motion to Continue Case Management Conference to October 3, 2013 and Related Deadlines Accordingly (Dkt. 15);

WHEREAS, Plaintiff has indicated that the time for service of judicial documents in China in accordance with the Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters ("Hague Service Convention") is estimated to take between four to seven months (Dkt. No. 17);

WHEREAS, Plaintiff served nominal Defendant Pacific Bepure Industry, Inc. on August 12, 2013 (Dkt. No. 19);

WHEREAS, Plaintiff is still awaiting confirmation from the Central Authority in China that service on Individual Defendants Haiting Li and Zhiyan Li is complete (as set forth in its Notice re: Status of Service on Defendants filed on August 26, 2013 (Dkt. No. 20)) and it is presently unclear when service will be deemed complete;

WHEREAS, to expedite the matter and avoid the expense and time of effectuating formal service, the Specially Appearing Defendants have agreed to be represented by the undersigned counsel of record, enter into a special appearance for purposes of this Stipulation, and waive formal service of process pursuant to Fed. R. Civ. P. Rule 4;

WHEREAS, Specially Appearing Defendants' special appearance and agreement to waive formal service of process is made with a reservation of all rights to contest venue and/or make other jurisdictional arguments along with a reservation of all other rights;

WHEREAS, the Parties have met and conferred and agree, that in light of the Specially Appearing Defendants' agreement to waive formal service and accept service, and given the challenges with obtaining facts and information relevant to the background of this matter including the location of the parties and document translation needs; and

WHEREAS, Fed. R. Civ. P. Rule 4(d)(1)(F) contemplates a 60-day period for a waiver of service by a defendant outside any judicial district of the United States;

IT IS HEREBY STIPULATED by the Parties through their undersigned counsel of record that the Specially Appearing Defendants will waive service and will answer or otherwise respond to Plaintiff's Complaint on or before November 1, 2013.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.