STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO DKT. NOS. 69 AND 70

HAYWOOD S. GILLIAM, Jr. District Judge.

Pursuant to Local Rule 6-2, the parties in this case, Enertrode, Inc. ("EnerTrode') and Linda Zhong ("Zhong") (together, "the EnerTrode Parties") and General Capacitor Co. Limited., Jianping Zheng aka Jim Zheng, General Capacitor International, Inc., General Capacitor, LLC (together, "General Capacitor") submit this stipulation to extend the time for General Capacitor to respond to: (a) the First Amended Answer of EnerTrode, Inc. to the General Capacitor's Counterclaim (Dkt. No. 69), and (b) First Amended Answer and Counterclaim of Linda Zhong (Dkt. No. 70) (together, the "EnerTrode Parties' First Amended Answers").

WHEREAS General Capacitor filed its Answer and Counterclaim (against EnerTrode) in this case on January 23, 2017 (Dkt. No. 37), to which EnerTrode answered and counterclaimed on February 20, 2017 (Dkt. No. 47);

WHEREAS Zhong filed a Complaint and Counterclaim (against General Capacitor) on February 7, 2017, as Dkt. No. 42 in (now-consolidated) Case No. 17-cv-179 HSG;

WHEREAS, through this Court's order at Dkt. No. 52 on March 1, 2017, this case has been consolidated with Case No. 17-cv-179 HSG (the "Consolidated Case');

WHEREAS General Capacitor filed their Answer to Zhong's Counterclaim (filed as Dkt. No. 42 in the now-Consolidated Case) on March 17, 2017 (Dkt. No. 58);

WHEREAS General Capacitor filed motions to strike the EnerTrode Parties' affirmative defenses set forth at Dkt. Nos. 42 (in the now-Consolidated Case) and Dkt No. 47 (in this case);

WHEREAS the EnerTrode Parties filed their First Amended Answers at Dkt. Nos. 69 and 70, in response to General Capacitor's operative pleadings;

WHEREAS the parties are meeting and conferring to discuss further motions to strike the EnerTrode Parties' First Amended Answers, in an attempt to resolve disputes and hopefully obviate the need for additional motions to strike (Declaration of Perry J. Narancic ISO Stipulation to Extend Time for Defendants to Respond to First Amended Answers of EnerTrode, Inc. and Linda Zhong ("Narancic Decl."), ¶ 4);

WHEREAS it is in the interest of judicial efficiency to permit the parties further time to resolve potential renewed Motions to Strike regarding the EnerTrode Parties' First Amended Answers;

WHEREAS the extension requested herein will not alter the date of any event or any deadline already fixed by Court order or the schedule in this case (Narancic Decl., ¶ 6);

NOW THEREFORE, the parties respectfully request that this Court order that the deadline for General Capcitor to respond to the EnerTrode Parties' First Amended Answers is extended to Friday May 19, 2017

IT IS SO STIPULATED.

[PROPOSED] ORDER

GOOD CAUSE appearing therefore, the deadline for the Genera Capacitor parties to respond to the EnerTrode Parties' First Amended Answers is extended to Friday May 19, 2017.

IT IS SO ORDERED.