SIXTH STIPULATION TO EXTEND TIME FOR FILING BRIEFS

EDWARD M. CHEN, District Judge.

COMES NOW, PIVOT POINT PARTNERS, LLC ("Pivot Point") by and through its attorneys of record, Tiemstra Law Group, PC; and Barry Milgrom, (the "Innocenti Trustee"), by and through his attorneys of record, and stipulate as follows:

WHEREAS, on September 8, 2015, Pivot Point filed a Notice of Appeal pursuant to 28 U.S.C. § 158(a) or (b) from the judgment, order, or decree of the Honorable Hannah L. Blumenstiel, United States Bankruptcy Judge, entitled Order Denying Motion for Relief from Stay entered on August 24, 2015;

WHEREAS, on September 8, 2015, Pivot Point filed a Statement of Election to Appeal to the District Court;

WHEREAS, on October 15, 2015, the Record on Appeal in was entered in the docket of this Court;

WHEREAS, on October 15, 2015, a scheduling order (the "Scheduling Order") was issued which advised the parties that appellant's brief was to be filed and served on or before November 16, 2015 (the "Opening Brief Deadline"), the appellee's brief was to be filed and served 20 days after service of appellant's brief, and appellant's reply brief was to be filed and served within 10 days after service of appellee's brief;

WHEREAS, around the time of the Scheduling Order deadlines, the parties were engaged in mediation through the United States Bankruptcy Court for the Northern District of California's Bankruptcy Dispute Resolution Program ("BDRP") (see Bankr. Local Rules 9040-1 et seq.), in an attempt to reach a global compromise of issues arising from the In re Innocenti and WB Coyle bankruptcy cases;

WHEREAS, given the then pending mediation, and in the interests of efficiency and judicial economy, the parties entered into a Stipulation to Extend Time for Filing Brief (Docket No. 5, filed Nov. 11, 2015), and this Court entered an Order extending the time to file the Opening Brief for sixty (60) days (Docket No. 6, entered, Nov. 13, 2015);

WHEREAS, on January 13, 2016, the parties entered into a second Stipulation to Extend Time for Filing Brief, agreeing to continue the time to file the Opening Brief for an additional sixty (60) days to allow time to document a settlement in preparation for approval by the Bankruptcy Court (Docket No. 9, filed Jan. 14, 2016), and this Court entered an Order extending the time to file the Opening Brief for sixty (60) days (Docket No. 10, entered Jan. 19, 2016);

WHEREAS, on March 15, 2016, the parties entered into a third Stipulation to Extend Time for Filing Brief, agreeing to continue the time to file the Opening Brief to and including April 8, 2016, to allow time to document a settlement in preparation for approval by the Bankruptcy Court (Docket No. 12, filed March 15, 2016), and this Court entered an Order extending the time to file the Opening Brief to and including April 8, 2016 (Docket No. 15, entered March 16, 2016);

WHEREAS, on April 8, 2016, the parties entered into a fourth Stipulation to Extend Time for Filing Brief, agreeing to continue the time to file the Opening Brief to and including May 6, 2016, to allow time to document a settlement in preparation for approval by the Bankruptcy Court (Docket No. 16, filed April 8, 2016), and this Court entered an Order extending the time to file the Opening Brief to and including May 6, 2016 (Docket No. 19, entered Apr. 11, 2016);

WHEREAS, on or about May 5, 2016, the parties entered into a fifth Stipulation to Extend Time for Filing Brief, agreeing to continue the time to file the Opening Brief to and including June 17, 2016, to allow time to document a settlement in preparation for approval by the Bankruptcy Court (Docket No. 21, filed May 6, 2016), and this Court entered an Order extending the time to file the Opening Brief to and including June, 2016 (Docket No. 23, entered May 6, 2016);

WHEREAS, due in part to ongoing contested matters in the bankruptcy case that is currently under submission, the parties have not finalized the settlement agreement but are continuing their efforts to do so;

WHEREAS, the parties agree that in the interests of efficiency and judicial economy, the Opening Brief Deadline should be extended to and including July 29, 2016, to allow completion of the documentation of the settlement agreement and approval by the Bankruptcy Court;

WHEREAS, all other deadlines set forth in the Scheduling Order shall remain the same; and

WHEREAS, the proposed order is attached hereto as Exhibit "A" and made a part hereof.

NOW, THEREFOR, IT IS HEREBY STIPULATED AND AGREED, by and between Pivot Point and the Innocenti Trustee, by and through their respective counsels of record, and in consideration of the forgoing, that the Opening Brief Deadline in the above-captioned appeal, shall be extended to and including July 29, 2016.

ATTESTATION

Pursuant to Civil Local Rule 5-1(i)(3), I hereby attest that I have concurrence in the filing of this document from Jennifer C. Hayes, pursuant to that certain email dated June 16, 2016, wherein Ms. Hayes authorized the use of a conformed signature.

EXHIBIT A

Upon the annexed Sixth Stipulation to Extend Time for Filing Briefs, the Court having reviewed the papers on file herein, being fully advised thereby and good cause appearing therefor,

IT IS HEREBY ORDERED, that the aforesaid Stipulation be, and the same is hereby, approved and adopted in its entirety as the order of this Court.

IT IS SO ORDERED.