JOINT STIPULATION AND [PROPOSED] ORDER FOR LEAVE FOR PLAINTIFFS TO FILE AND SERVE A SECOND AMENDED COMPLAINT

EDWARD M. CHEN, District Judge.

Pursuant to Federal Rule of Civil Procedure 6 and Local Rule 6, Plaintiffs iCORE Global, LLC ("iCORE"), iCG-Denver, LLC ("iCG-Denver") and Samantha Mueting (collectively, "Plaintiffs") and Defendants Millennium Commercial Advisors, LLC ("Millennium"), Avison Young (Canada) Inc. ("Avison Young (Canada)"), Avison Young (USA) Inc. ("Avison Young (USA)"), Avison Young — Northern California, Ltd. ("Avison Young — Northern California"), Alec Wynne ("Wynne"), and Justin Rayburn ("Rayburn") (collectively, "Defendants"), hereby stipulate as follows:

WHEREAS:

1. Defendants Avison Young (Canada), Avison Young (USA), and Avison Young — Northern California filed a Motion to Dismiss on October 31, 2014 ("Motion to Dismiss"), and a hearing was set initially for December 11, 2014 at 1:30 pm in Courtroom 5, 17th Floor, San Francisco. (Dkt. No. 30).

2. Defendants Millennium, Wynne, and Rayburn filed a Motion to Stay on October 31, 2014 ("Motion to Stay"), and a hearing was set initially for December 11, 2014 at 1:30 pm in Courtroom 5, 17th Floor, San Francisco. (Dkt. No. 33).

3. The initial deadline for Plaintiffs to respond to both the Motion to Dismiss and the Motion to Stay was November 14, 2014. On November 17, 2014, the Court granted a joint stipulation to reset the response date to November 24, 2014. (Dkt. No. 38). The Court also reset subsequent deadlines as follows:

4. In lieu of responding to the Motion to Dismiss, Defendants have agreed to a proposal by Plaintiffs to file and serve a Second Amended Complaint ("SAC") by December 19, 2014. Defendants Avison Young (Canada), Avison Young (USA), and Avison Young — Northern California will no longer be required to file a reply by December 11, 2014.

5. Defendants will respond to the SAC within 21 days after service of the SAC.

6. Plaintiffs also agree that the SAC will no longer name iCG-Denver as a plaintiff, and will therefore not name iCG-Denver as a plaintiff in this case.

7. The current briefing schedule regarding the Motion to Stay will be maintained:

8. No other requests for continuances have been made as to Plaintiffs' responses to the Motion to Dismiss and the Motion to Stay, Defendants' replies to Plaintiffs' responses, or the hearing date for either motion, except as set forth herein.

9. The parties agree that Plaintiffs and Defendants are not waiving any available defenses, arguments, or motions by entering into this stipulation.

IT IS SO STIPULATED.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.