JOINT STIPULATION AND PROPOSED ORDER EXTENDING TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S AMENDED COMPLAINT

SAUNDRA B. ARMSTRONG, District Judge.

WHEREAS, R. Todd Neilson, as Liquidating Trustee on behalf of Solyndra Residual Trust ("Solyndra" or "Plaintiff") filed an Amended Complaint in the above-captioned case against Defendants Suntech Power Holdings Co., Ltd. ("Suntech Holdings"), Suntech America Inc., Trina Solar Limited, Trina Solar (U.S.), Inc., Yingli Green Energy Holding Company Limited, and Yingli Green Energy Americas, Inc. (collectively, "Defendants" and without Suntech Holdings, "Answering Defendants") on February 14, 2013 (Dkt. 70, the "Amended Complaint");

WHEREAS, Defendants filed a joint Motion to Dismiss all of Plaintiff's claims on March 8, 2013 (Dkt. 74);

WHEREAS, the Parties received notice that the Court had denied Defendants' joint Motion to Dismiss on April 9, 2014 (Dkt. 87);

WHEREAS, pursuant to the Court's order of February 13, 2013 (Dkt. 71) and Federal Rule of Civil Procedure 12(a)(4), Answering Defendants were required to answer Plaintiff's Amended Complaint on April 23, 2014;

WHEREAS, the Parties, through their counsel, have conferred and agreed for the convenience of the Parties, after considering the length of Plaintiff's Amended Complaint, to extend Answering Defendants' deadline to answer or otherwise respond to Plaintiff's Amended Complaint by two weeks;

NOW, THEREFORE, SUBJECT TO THE COURT'S APPROVAL, Suntech America, Inc.; Trina Solar Limited; Trina Solar (U.S.), Inc.; Yingli Green Energy Holding Company Limited; Yingli Green Energy Americas, Inc. and Solyndra hereby stipulate and agree that the Answering Defendants' deadline to answer or otherwise respond to Plaintiff's Amended Complaint will be May 7, 2014.

The parties have previously requested four time modifications from the Court: (i) extending time to respond to Plaintiff's first complaint and implementing a stipulated briefing schedule (Dkt. 21); (ii) granting a one-week extension for Defendants' opposition to Plaintiff's motion for early discovery, in light of the holidays (Dkt. 33); (iii) extending time for Defendants to respond to Plaintiff's first complaint, in light of Plaintiff's expressed intent to file an amended complaint (Dkt. 54); and (iv) extending time to respond to Plaintiff's Amended Complaint in light of Defendants' intent to file a joint motion to dismiss (Dkt. 71). The stipulated requested modification would not otherwise alter the schedule for this case, except as set out above.

PROPOSED ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.