STIPULATION AND [PROPOSED] ORDER GRANTING FIRST REQUEST BY PLAINTIFF FOR EXTENSION OF TIME FOR OPPOSITION TO DEFENDANTS' MOTIONS TO TRANSFER VENUE AND DISMISS THE COMPLAINT; DECLARATION OF ALEX RICE KERR

RICHARD SEEBORG, District Judge.

Pursuant to Local Rule 6-2, Plaintiff Viesti Associates, Inc. ("Viesti") and Defendants McGraw-Hill Global Education Holdings, LLC and McGraw-Hill School Education Holdings, LLC ("MHE"), by and through their respective undersigned counsel, stipulate to, and respectfully request that the Court enter, an Order extending Viesti's time to file oppositions to MHE's motions (1) to transfer venue pursuant to 28 U.S.C. § 1404(a) (Doc. 16); and (2) to dismiss pursuant to Fed. R. Civ. P. 12(b)(6) (Doc. 17). In support of the Stipulation, Viesti respectfully submits the Declaration of Alex Rice Kerr, and the Parties state as follows:

1. MHE filed its motions to transfer venue, and to dismiss, on January 26, 2017.

2. Viesti's oppositions to the motions are currently due on or before February 9, 2017.

3. Viesti seeks a 14-day extension of time up to and including February 23, 2017 to file its oppositions to the motions to transfer venue and to dismiss. Viesti requests this extension to give it adequate time to respond to the various issues raised by MHE's motions.

4. Viesti also requests that the Court re-set the March 9, 2017 hearing on the motions to March 23, 2017.

5. Viesti has not previously requested any extension of time for filing its oppositions.

6. MHE's counsel does not oppose Viesti's requested extension. WHEREFORE, the parties respectfully request entry of the Proposed Order below.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

CERTIFICATE OF CONCURRENCE IN FILING

Pursuant to Local Rule 5(i)(3), I hereby certify that concurrence in the filing of the foregoing Stipulation has been obtained from each of the other signatories.

DECLARATION OF ALEX RICE KERR

1. I, Alex Rice Kerr, make this declaration pursuant to 28 U.S.C. § 1746 in support of the Stipulation between Plaintiff Viesti Associates, Inc. ("Viesti") and Defendants McGraw-Hill Global Education Holdings, LLC and McGraw-Hill School Education Holdings, LLC ("MHE"), and the parties' request that the Court enter an Order extending Viesti's time to file oppositions to MHE's motions (1) to transfer venue pursuant to 28 U.S.C. § 1404(a) (Doc. 16); and (2) to dismiss pursuant to Fed. R. Civ. P. 12(b)(6) (Doc. 17). I have personal knowledge of the facts stated herein and if called upon could testify to them.

2. MHE filed its motions to transfer venue, and to dismiss, on January 26, 2017.

3. Viesti's oppositions to the motions are currently due on or before February 9, 2017.

4. Viesti seeks a 14-day extension of time up to and including February 23, 2017 to file its oppositions to the motions to transfer venue and to dismiss. Viesti requests this extension to give it adequate time to respond to the various issues raised by MHE's motions.

5. Viesti also requests that the Court re-set the March 9, 2017 hearing on the motions to March 23, 2017.

6. Viesti has not previously requested any extension of time for filing its oppositions.

7. MHE's counsel does not oppose Viesti's requested extension. I declare under penalty of perjury that the foregoing is true and correct.

Executed on February 2, 2017