[PROPOSED] ORDER AND STIPULATION GRANTING THE RECEIVER'S REQUEST FOR A FURTHER EXTENSION OF TIME WITHIN WHICH TO FILE A PROPOSED PLAN OF LIQUIDATION

EDWARD M. CHEN, District Judge.

The parties, U.S. Securities & Exchange Commission, counsel for defendants Saddle River Advisers, LLC ("Saddle River") and SRA Management Associates, LLC ("SRA Management"), and counsel for the Receiver, hereby stipulate and agree to the entry of an order as follows:

1.) The Receiver in this matter, Sherwood Partners, Inc. has been diligently working since the Court's previous grant of an extension of time within which to file a Plan of Liquidation ("Plan") in its Order granting an extension (" Extension Order") dated January 3, 2017. The Extension Order amended the language of Section XIII of this Court's Order Appointing Receiver (Docket No. 142) to permit the receiver to file a plan within 180 days of being appointed, or by April 11, 2017. (Counsel for the Receiver was to have subsequently e-filed a proposed amended Order for the Court's approval, which through inadvertence by counsel, has not yet been filed. The grant of this proposed stipulation and order requesting additional time will in any event supersede the earlier grant of an extension, and counsel for the Receiver will not fail again to file any proposed order encompassing the extension.)

2.) Through on-going settlement negotiations, the Receiver and the staff of the plaintiff Securities and Exchange Commission have been working to develop a comprehensive Plan which would treat investors and creditors fairly, but would also incorporate and adhere to the apparent discrepancies that exist between the available pre-IPO (and in the case of Square Inc., post IPO) inventory of stock in the possession of the Receiver, and the expectations of the investors and creditors as to the assets to which they believed they were entitled.

3.) The Receiver is currently examining these discrepancies, which suggest a possible shortfall in the available stock of both Square and Palantir sufficient to satisfy investor's expectations, as well as investigating the extent of commingling of money and assets by the receivership entities. To the extent that there are shortfalls and commingling of investor money and holdings, then a consolidation of receivership assets and a pro rata distribution of those assets might be appropriate.

4.) In light of the foregoing, the Receiver needs additional time within which to complete its investigation and discovery in order to come to the Court with a viable, and equitable Plan. It is the Receiver's current expectation that up to another two months, or until June 12, 2017, should be available for the Receiver, with the support of the Securities and Exchange Commission, to file a proposed Plan.

5.) The Plaintiff Securities & Exchange Commission and counsel for defendants Saddle River and SRA Management, on being informed of the above by the Receiver's counsel have stated that they do not object to again amending the second sentence of Sec. XIII of this Court's order Appointing Receiver (Docket No. 142) as follows:

6.) Based on the parties agreement, the Court will amend the language of Sec. XIII as agreed above and issue and amended Order concerning the filing of the plan of liquidation contained in Docket No. 142.

SO STIPULATED.

Pursuant to Civil L.R. 5.1, I hereby attest that I have on file all holographic signatures corresponding to any signatures indicated by a conformed signature (/S/) within this e-filed document.

IT IS SO ORDERED.