JOINT STIPULATION AND [PROPOSED] ORDER TO RESET CASE MANAGEMENT CONFERENCE HEARING

EDWARD M. CHEN, District Judge.

Pursuant to Federal Rule of Civil Procedure 6 and Local Rules 6-2 and 7-12, Plaintiffs iCORE Global, LLC ("iCORE") 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 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 were no longer required to file a reply by December 11, 2014.

5. Defendants responded to the SAC on January 9, 2015.

6. Defendants filed their reply to their Motion to Stay on December 11, 2014.

7. The Court reset the Case Management Conference from January 29, 2015 to February 26, 2015 on January 12, 2015.

8. The Court granted Defendants' Motion to Stay ("Order on the Motion to Stay") on January 14, 2015 pending the Colorado trial court issuing an order on the question of the enforceability of the forum selection clauses in the iCORE contracts. (Dkt. No. 050).

9. On January 15, 2015, the Court reset the Case Management Conference from February 26, 2015 to June 11, 2015. The Joint Case Management Statement is due by June 4, 2015. (Dkt. No. 51.)

10. Pursuant to the Court's Order on the Motion to Stay, the Parties have met and conferred and set August 31, 2015 for the exchange of initial disclosures.

11. As the Colorado trial court proceeding is still pending, the Parties hereby stipulate to resetting (1) the date of the June 11, 2015 Case Management Conference, and (2) the June 4, 2015 deadline for filing the Joint Case Management Statement, and extending those dates for at least an additional ninety days, subject to the Court's approval.

12. Resetting the date of the Case Management Conference and the deadline for the Joint Case Management Statement will not have an adverse effect on the case schedule as the case is currently stayed.

13. 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.

SIGNATURE ATTESTATION

Pursuant to Civil Local Rule 5-1(i)(3), the undersigned filer of this document attests that concurrence in the filing of this document has been obtained from each of the other signatories.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, THE CASE MANAGEMENT CONFERENCE IS RESET FROM JUNE 11, 2015 TO October 22, 2015. THE JOINT CASE MANAGEMENT STATEMENT WILL BE DUE BY Oct. 15, 2015. IT IS SO ORDERED.

IT IS SO ORDERED AS MODIFIED.