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1 Case :0-cv-0-GAF -CT Document Filed 0// Page of Page ID #: 0 S. FIGUEROA ST., SUITE 00 LOS ANGELES, CALIFORNIA 00- TELEPHONE ( -00 FAX ( - Andrew R. Hall (CA SBN andyhall@dwt.com Catherine E. Maxson (CA SBN 0 catherinemaxson@dwt.com OF COUNSEL: BROADWAY NEW YORK, NEW YORK 00-0 TELEPHONE ( -0 FAX ( -0 Victor A. Kovner (NY SBN victorkovner@dwt.com 0 THIRD AVENUE, SUITE 00 SEATTLE, WASHINGTON 0-0 TELEPHONE (0-0 FAX (0-00 Stuart R. Dunwoody (WA SBN (admitted pro hac vice stuartdunwoody@dwt.com Attorneys for Plaintiffs UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 0 DAVID CASSIRER, AVA CASSIRER, and UNITED JEWISH FEDERATION OF SAN DIEGO COUNTY, a California non-profit corporation, vs. Plaintiffs, THYSSEN-BORNEMISZA COLLECTION FOUNDATION, an agency or instrumentality of the Kingdom of Spain, Defendant. Case No. CV 0--GAF (CTx STIPULATION REGARDING CONTINUANCE OF TRIAL DATE AND PRETRIAL DEADLINES Date: N/A Time: N/A Dept.: N/A The Honorable Gary Allen Feess DWT v

2 Case :0-cv-0-GAF -CT Document Filed 0// Page of Page ID #:0 0 0 STIPULATION This Stipulation is entered into by the parties through their undersigned counsel of record, as follows:. WHEREAS the current Scheduling and Case Management Order, entered August, 0, sets a trial date of July, 0, a discovery cutoff of April, 0, and an expert disclosure deadline of January, 0;. WHEREAS the Defendant filed its motion to dismiss the complaint on September, 0, argument on the motion was heard on January, 0, and the motion to dismiss is under consideration;. WHEREAS to conserve resources the parties have postponed depositions, some of which will likely take place outside the U.S., pending the outcome of the motion to dismiss;. WHEREAS the parties will need to conduct additional fact discovery before they will be able to prepare expert reports in compliance with Fed. R. Civ. P. (a(; and. WHEREAS to conserve resources the parties wish to postpone preparation of expert reports until after the Court has ruled on the motion to dismiss. WHEREFORE, the parties stipulate as follows:. The parties respectfully request that the trial date be continued by ninety days, to October, 0, and that the pre-trial deadlines be similarly extended. DWT v S. FIGUEROA ST, SUITE 00 LOS ANGELES, CALIFORNIA 00- ( -00 Fax: ( -

3 Case :0-cv-0-GAF -CT Document Filed 0// Page of Page ID #: 0 0 DATED: January, 0. DATED: January, 0. STUART R. DUNWOODY ANDREW R. HALL CATHERINE E. MAXSON By: s/stuart R. Dunwoody Stuart R. Dunwoody Attorneys for Plaintiff CLAUDE CASSIRER NIXON PEABODY LLP THADDEUS J. STAUBER KELLY L. KRESS By: s/thaddeus J. Stauber Thaddeus J. Stauber Attorneys for Defendant THYSSEN- BORNEMISZA COLLECTION FOUNDATION DWT v S. FIGUEROA ST, SUITE 00 LOS ANGELES, CALIFORNIA 00- ( -00 Fax: ( -

4 Case :0-cv-0-GAF -CT Document Filed 0// Page of Page ID #: 0 0 DWT v PROOF OF SERVICE I am employed in the County of King, State of Washington. I am over the age of and not a party to the within action. My business address is Davis Wright Tremaine LLP, Suite 00, 0 Third Avenue, Seattle, WA 0-0. On January, 0, I caused the following document described as: OF TRIA DATE AND PRETRIAL DEADLINES to be filed electronically with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the interested parties in this action or proceeding, or by placing a true copy of said document(s enclosed in a sealed envelope(s for parties that are not on the notice list addressed as below, with the name and address of the person served shown on the envelope as follows: Thaddeus J. Stauber Kelly L. Kress Nixon Peabody LLP Gas Company Tower West Fifth Street, th Floor Los Angeles, CA 00 Tel: ( -000 Fax: ( tstauber@nixonpeabody.com kkress@nixonpeabody.com Attorneys for Defendant Thyssen-Bornemisza Collection Foundation U.S. Mail Hand Delivery Overnight Mail Facsimile x CM/ECF Notice I placed such envelope(s with postage thereon fully prepaid for deposit in the United States Mail in accordance with the office practice of Davis Wright Tremaine LLP, for collecting and processing correspondence for mailing with the United States Postal Service. I am familiar with the office practice of Davis Wright Tremaine LLP, for collecting and processing correspondence for mailing with the United States Postal Service, which practice is that when correspondence is deposited with the Davis Wright Tremaine LLP personnel responsible for delivering correspondence in the United States Postal Service, such correspondence is delivered to the United States Postal Service that same day in the ordinary course of business. S. FIGUEROA ST, SUITE 00 LOS ANGELES, CALIFORNIA 00- ( -00 Fax: ( -

5 Case :0-cv-0-GAF -CT Document Filed 0// Page of Page ID #: Executed on January, 0. State I declare under penalty of perjury, under the laws of the State of Washington, that the foregoing is true and correct. Federal I declare under the penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that I am employed in the office of Davis Wright Tremaine LLP and Stuart R. Dunwoody, admitted pro hac vice, at whose direction the service was made. s/marilyn N. Boyd Marilyn N. Boyd 0 0 DWT v S. FIGUEROA ST, SUITE 00 LOS ANGELES, CALIFORNIA 00- ( -00 Fax: ( -