STIPULATION TO CONTINUE MOTION OF ASSOCIATED THIRD PARTY ADMINISTRATORS TO ALTER, AMEND AND/OR RECONSIDER JUDGMENT PURSUANT TO F.R.C.P. RULE 59(e), OR IN THE ALTERNATIVE, FOR RELIEF FROM JUDGMENT PURSUANT TO F.R.C.P. RULE 60(b)(6);

DECLARATION OF ALAN M. MIRMAN RE SIGNATORY'S CONCURRENCE IN ELECTRONIC FILING;

[PROPOSED] ORDER RE STIPULATION

EDWARD M. CHEN, District Judge.

Respondent ASSOCIATED THIRD PARTY ADMINISTRATORS ("ATPA") and Petitioner RICHARD STEIRWALT ("Stierwalt"), through their respective counsel undersigned, stipulate as set forth herein:

RECITALS

A. On May 24, 2016, the Court entered in the above-captioned action its Order Re Third-Party Claim Of Security Interest (the "Original Order") [Docket No. 23] and a Judgment (the "Original Judgment") [Docket No. 24], adjudicating the third-party claim (the "Third-Party Claim") of CAMOFI Master LDC and CAMHZN Master LDC in favor of Stierwalt.

B. On May 25, 2016, the Court entered a Corrected Order Re Third-Party Claim Of Security Interest (the "Corrected Order") [Docket No. 25], and a corrected Judgment [Docket No. 26] which referred to the Corrected Order instead of the Original Order as the basis therefor.

C. On June 22, 2016 ATPA filed a Motion to Alter, Amend and/or Reconsider Judgment Pursuant to F.R.C.P. Rule 59(e), or in the Alternative, for Relief from Judgment Pursuant to F.R.C.P. Rule 60(b)(6) (the, "Motion") and set the hearing for its Motion for July 28, 2016 at 1:30 p.m.

D. Counsel for Stierwalt has advised counsel for ATPA that the former will be out of state on July 28, 2016 and has asked for a short continuance of the Court's hearing on the Motion to accommodate the travel schedule of counsel for Stierwalt, with no change in the parties' briefing schedule. Counsel for ATPA has agreed to the requested continuance.

STIPULATION

Based on the foregoing recitals, the parties through their respective counsel undersigned hereby stipulate to continue the hearing on ATPA's Motion to Alter, Amend, and/or reconsider Judgment Pursuant to F.R.C.P. Rule 59(e), or in the Alternative, for Relief from Judgment Pursuant to F.R.C.P. Rule 60(b)(6) from July 28, 2016 to August 4, 2016 at 1:30 p.m. or soon thereafter as the Court may schedule per further conference between the Court, Stierwalt, and ATPA. The parties' briefing deadlines in connection with the Motion remain as currently scheduled.

DECLARATION OF ALAN M. MIRMAN

I, Alan M. Mirman, declare:

1. I am an attorney at Mirman, Bubman & Nahmais, LLP, attorneys of record in the above-captioned action for respondent Associated Third Party Administrators. I am admitted to practice law before this Court. I have personal knowledge of the matters set forth herein and if called as a witness could and would competently testify thereto.

2. This declaration is filed pursuant to Civil L.R. 5-1(i)(3) in support of the parties' stipulation set forth above (the "Stipulation").

3. I have obtained concurrence in the parties' filing of the Stipulation in this action from Eric A. Handler, one of the attorneys of record in this action for petitioner Richard Stierwalt, and Mr. Handler's electronic signature is given in the Stipulation in accordance with his concurrence.

I declare under penalty of perjury under the laws of the State of California and the United States of America that the foregoing is true and correct and that this declaration has been executed on July 6, 2016 in Woodland Hills, California.

ORDER

Based on the foregoing Stipulation of the parties, and good cause appearing therefore, it is hereby ordered that the Court's hearing on the Motion of Respondent Associated Third Party Administrators to Alter, Amend, and/or Reconsider Judgment Pursuant to F.R.C.P. Rule 59(e), or in the Alternative, for Relief from Judgment Pursuant to F.R.C.P. Rule 60(b)(6) is continued from July 28, 2016 to August 4, 2016 at 1: 30p.m. The briefing deadlines remain as currently scheduled.

PURSUANT TO STIPULATION, IT IS SO ORDERED.