STIPULATION AND [PROPOSED] ORDER GRANTING NON-PARTY TELESOFT CAPITAL, LLC'S ADMINISTRATIVE MOTION TO REQUEST NOTICE AND AN OPPORTUNITY TO BE HEARD

EDWARD M. CHEN, District Judge.

WHEREAS, on October 11, 2016, the Court entered an order for appointment of Receiver in the above-captioned action ("Receiver Order", Dkt. #142);

WHEREAS, before the Court is an administrative motion to confirm that non-party TeleSoft Capital, LLC (the "Non-Party") is entitled to notice and an opportunity to be heard before the Receiver approves, negotiates for the sale or transfers pre-IPO shares of Palantir Technologies, Inc. ("Palantir"), pursuant to Sections IX and XIV of the Receiver Order (the "Motion");

WHEREAS, Plaintiff and the Receiver do not take any position on the representations made in Non-Party's Motion;

NOW, THEREFORE, Plaintiff, the Receiver and Non-Party, by and through their undersigned counsel, hereby agree and stipulate as follows:

1. If the Receiver requests the Court's approval for sales of Palantir shares from the Set-Aside Fund, Non-Party is entitled to two-weeks expedited notice, with any opposition by Non-Party due in writing five court days after the Receiver's expedited motion;

2. In accordance with this Order, the Clerk shall add Non-Party's undersigned counsel to an ECF user in the above-captioned action.

E-FILER'S ATTESTATION

Pursuant to Civil Local Rule 5.1(i)(3), the undersigned attests that parties to this Stipulation have concurred in the filing of this STIPULATION AND [PROPOSED] ORDER GRANTING NON-PARTY TELESOFT CAPITAL, LLC'S ADMINISTRATIVE MOTION TO REQUEST NOTICE AND AN OPPORTUNITY TO BE HEARD.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDER.