JOINT STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE SECOND AMENDED COMPLAINT

HAYWOOD S. GILLIAM, JR., District Judge.

Plaintiff DAVID McDONALD and Defendants INSPERITY PEO SERVICES, L.P.(hereinafter, "Insperity") and APOLLO GLOBAL MANAGEMENT, LLC (hereinafter, "Apollo") (hereinafter collectively, the "Parties") hereby stipulate as follows:

WHEREAS, this putative class action was initiated on August 24, 2017, when Plaintiff filed the Class Action Complaint;

WHEREAS, the case was assigned to the Honorable Sallie Kim;

WHEREAS, Plaintiff filed the First Amended Complaint on September 14, 2017;

WHEREAS, Defendant Insperity filed its Answer to the First Amended Complaint on October 10, 2017;

WHEREAS, Defendant CP OpCo, LLC, doing business as Classic Party Rentals failed to respond to the First Amended Complaint, and default was entered as to Defendant CP OpCo, LLC, doing business as Classic Party Rentals on October 23, 2017;

WHEREAS, pursuant to Rule 12(a)(1)(A)(i) of the Federal Rules of Civil Procedure, Apollo originally had until October 10, 2017 to file a response to the First Amended Complaint;

WHEREAS, the Parties previously stipulated on October 10, 2017 that Apollo would have an additional twenty (20) days to respond to the Complaint, until October 30, 2017;

WHEREAS, the Parties subsequently stipulated that Apollo would have an additional three (3) weeks in which to respond to the Complaint, until November 20, 2017, because it was Apollo's position that the three additional weeks were necessary in order to provide Apollo with sufficient time to provide additional information to Plaintiff in connection with Plaintiff's claims; and

WHEREAS, Apollo has now provided Plaintiff with additional information;

NOW THEREFORE, the parties hereby stipulate and agree that:

Attestation of Consent to File

Pursuant to Rule 5-1(i)(3) of the local rules of this Court, I, John T. Mullan, hereby attest that I obtained concurrence in the filing of this document from each of the other signatories listed above.

ORDER

Plaintiff is hereby granted leave to file a Second Amended Complaint in this lawsuit for purposes of adding Apollo Centre Street Partnership, L.P.; Apollo Franklin Partnership, L.P.; Apollo Credit Opportunity Fund III AIV I, LP; Apollo SK Strategic Investments, L.P.; Apollo Special Opportunities Managed Account, L.P.; and Apollo Zeus Strategic Investments, L.P. as Defendants in this matter.

PURSUANT TO STIPULATION, IT IS SO ORDERED.