AGREED JOINT MOTION TO STAY PRELIMINARY INJUNCTION BRIEFING AND ARGUMENT AND PROPOSED ORDER

CAM FEENBACH, Magistrate Judge.

Plaintiff Federal Trade Commission ("FTC") and Defendants AMG Services, Inc., SFS, Inc., Red Cedar Services, Inc., MNE Services, Inc., Scott A. Tucker, Blaine A. Tucker, AMG Capital Management, LLC, Level 5 Motorsports, LLC, LeadFlash Consulting, LLC, Black Creek Capital Corporation, Broadmoor Capital Partners, LLC, Don E. Brady, Robert D. Campbell, and Troy L. Littleaxe (collectively, "Defendants") respectfully request that the Court stay further briefing and argument regarding the FTC's motion for preliminary injunction (Docket No. 4.):

1. The parties have reached agreement on a stipulated preliminary injunction and an agreement to bifurcate this case into two phases: (1) merits/liability; and if necessary (2) common enterprise liability, individual liability, and relief.

2. Both the stipulated preliminary injunction and bifurcation promote the orderly resolution of controversy and judicial economy.

3. The parties' proposed order for a stipulated preliminary injunction and bifurcation of discovery has been submitted to United States District Judge Gloria M. Navarro for approval.

4. The parties agree that, pending Judge Navarro's review of the parties' proposed order, further briefing and argument regarding the FTC's motion for preliminary injunction would waste the Court's and the parties' resources.

5. The parties agree that if their proposed order for a stipulated preliminary injunction and bifurcation is not approved, they will, within seven days, meet and confer and submit a proposal to the Court to reschedule the motion for preliminary injunction briefing and argument.

The parties therefore respectfully request that the Court stay all further briefing and argument regarding the FTC's motion for preliminary injunction (Docket No. 4).

IT IS SO ORDERED: