JOINT LETTER BRIEF AND STIPULATION RE: COMPLIANCE WITH COURT'S ORDER RE: WITHDRAWAL OF COUNSEL FOR THE KLIMOV DEFENDANTS [DKT. 243]; [PROPOSED] ORDER

Local Rule 6-2

EDWARD M. CHEN, District Judge.

Pursuant to the United States District Court, Northern District of California Local Rules, Rule 6-2 and the Court's Order re Defense Counsel Declarations and Plaintiff's Notice (Dkt. 243), Benjamin Davidson, attorney for plaintiff Artec Group, Inc. ("Artec" or "Plaintiff"); Oly Filatova and Igor Shoiket, present counsel (pending the grant of their withdrawal) for defendants Andrey Klimov, Yulia Klimova, Anna Stebleva, A-Star LLC, and ID-Wise SIA (the "Klimov Defendants"), state and stipulate as follows:

1. On March 29, 2017, the hearing on the motions to withdraw filed by counsel for the Klimov Defendants (as well as by counsel for co-defendant Axon Business Systems) came before the aforementioned Court, the Hon. Edward M. Chen, District Judge, presiding.

2. On April 4, 2017, the Court conditionally granted the motions to withdraw The granting of the motions was conditioned on, e.g., (1) each individual defendant registering for an ECF account; (2) each entity defendant providing an email address to be added to the ECF system for purposes of service; (3) to return AEO documents to Artec should no new counsel make an appearance on behalf of their clients by a date certain and (4) withdrawing counsel to file declarations related to their compliance with the above. See Dkt. 225, 243.

3. On April 28, 2017, Ms. Filatova filed a Declaration in Compliance with 4/4/2017 Court Order (Dkt. 238). On May 2, 2017, Artec filed a Notice of Defense Counsel's Noncompliance with Court Order of April 3, 2017 and Declaration of Benjamin Davidson, Dkt. 240, 240-1.

4. On May 3, 2017, the Court issued an Order re Defense Counsel Declarations and Plaintiff's Notice. Dkt. 243. The Court directed the parties to meet and confer regarding the alleged failure to comply and, within a week, to file a joint brief providing an update for the Court and, if appropriate, a stipulation and proposed order.

5. Counsel for Plaintiff and the Klimov Defendants have met and conferred in good faith regarding the Court's Order. Following the met and confer, counsel have agreed and STIPULATED to the following:

a. Should none of the Klimov Defendants retain new counsel by May 12, 2017, present counsel will return all production CDs and hard copies containing documents or other materials produced by Plaintiff in disclosure or discovery that has been designated "HIGHLY CONFIDENTIAL—ATTORNEYS EYES ONLY" or "HIGHLY CONFIDENTIAL—SOURCE CODE" (collectively, "AEO materials"), including documents/materials that were re-designated as AEO materials after the Stipulated Protective Order, as modified, was executed (Dkt. 165).

b. Should none of the Klimov Defendants retain new counsel by May 12, 2017, present counsel will return or delete all files and correspondences containing AEO materials from their hard drives and servers, and also shall ensure that the same are returned/deleted from the hard drives, servers, and files of anyone else who has viewed or had access to these materials.

c. Should any of the Klimov Defendants retain new counsel by May 12, 2017, all AEO materials will be provided to new counsel, who shall be made aware of the Stipulated Protective Order and the restrictions on disclosing Plaintiff's AEO materials to the Individual Defendants set forth therein and in the Court's subsequent Orders.

d. The Parties further agree that that present counsel may have until May 15, 2017 to perform the acts set forth in 6(a)-(c) and that unless present counsel receives confirmation from the Klimov Defendants on or before May 15, 2017 that they have retained new counsel, they will return Plaintiff's production CDs to the San Francisco offices of Jeffer Mangels Butler & Mitchell on May 15, 2017 by hand-delivery or by overnight mail with tracking.

e. Present counsel for the Klimov Defendants shall file a Notice of Compliance affirming compliance with the aforementioned to the same extent as set forth in the Court's Order of April 4, 2017 (Dkt. 225). To the extent practicable, counsel shall endeavor to obtain the concurrence of counsel for Plaintiff prior to filing the Notice of Compliance. Such stipulation shall be filed no later than Wednesday, May 17, 2017.

IT IS SO STIPULATED Page 6>

[PROPOSED] ORDER

Good cause appearing, IT IS HEREBY ORDERED that the time periods and conditions for compliance with the Court's Order Conditionally Granting Defense Counsel's Motions to Withdraw (Dkt. 225) shall be amended and extended to the extent set forth in the foregoing Stipulation.

IT IS SO ORDERED.