individually and collectively, have consulted and concurred on the extensions of time set forth in this Stipulated Order, and therefore respectfully submit this Stipulated Order to establish the following briefing timetable:

1. Plaintiffs shall have an extension of time, through and including December 7, 2000, to file responsive pleadings to any Motions to Dismiss presently on file by the above-listed Defendants.

2. The EFF Defendants, individually and collectively, shall have until December 7, 2000 to file any motions, responsive pleadings, or other papers that the EFF Defendants shall deem fit, in response to or addressing the Plaintiffs’ Motion For an Order To Publish Notice of Action.

3. Through and including the date(s) of filing of any Motions, opposition papers, reply briefs, or other papers set forth in Paragraph 2, or responsive thereto, and any Ruling by this Court upon any papers filed in accordance with Paragraph 2, the Court’s Order To Publish Notice of Action, is hereby STAYED, and Plaintiff shall take no further action under such Order.

4. Any actions in accordance with the Court’s Order To Publish Notice of Action

The Electronic Frontier Foundation (“EFF”) has recently learned of this lawsuit, and has assembled a team of lawyers to represent these defendants (along with a handful of other defendants who either have not yet been served or who otherwise are not subject to the pending filing deadline) pro bono publico. The EFF defense team expects shortly to secure authorization from most or all of the above-listed defendants (1) to defend them in this lawsuit, and (2) to maintain a multiple representation of parties whose interests in defending this lawsuit are principally aligned.

Accordingly, in order to conduct the necessary pre-filing investigation, to secure the necessary authorizations and waivers, and to prepare responsive pleadings, the EFF defense team have contacted Plaintiff’s counsel and requested a modest 14-day extension of time. Plaintiff’s counsel do not object to the requested extension.

WHEREFORE, the above-listed Defendants respectfully pray for an extension of time, to and including November 2, 2000, to Answer or Move in accordance with Rule 12 of the Federal Rules of Civil Procedure.

Dated: October 18, 2000. Respectfully submitted,

_____________________

Eric C. Grimm (MI Bar No. P58990)

CyberBrief, PLC

320 South Main Street

Ann Arbor, Michigan 48107-7341

734.332.4900

Fax 734.332.4901

David Lowenschuss

David H. Lowenschuss, PLC

2020 Shadford Road

Ann Arbor, MI 48104

Cindy Cohn

Legal Director

Electronic Frontier Foundation

1550 Bryant Street, Suite 725

San Francisco, CA 94103

415.436.9333

Certificate of Service

I certify that I served the foregoing Unopposed Motion For Extension of Time, upon the following parties and counsel of record, by first class mail, postage prepaid, on Wednesday, October 18, 2000:

Gregory D. Phillips, Esq. John E. S. Scott, Esq.

Howard, Phillips & Anderson Dickinson, Wright, PLLC

560 East 200 South, Suite 230 500 Woodward Avenue, Suite 4000

Salt Lake City, Utah 84102 Detroit, Michigan 48226

Luis Miguel Acosta, Esq. William A. Sankbeil, Esq.

505 North Woodward Kerr, Russel & Weber, PLC

Suite 3000 500 Woodward Avenue, Suite 2500

Bloomfield Hills, Michigan 48304 Detroit, Michigan 48226-3406

Wallace W. Rawson Robert R. Yoder

2858 Bernice Avenue 5808 N. 40th Street, Suite 335

Lansing, IL 60438 Phoenix, AZ 85018

David Lowenschuss, Esq. Cindy Cohn, Esq.

David H. Lowenschuss, PLC Legal Director

2020 Shadford Road Electronic Frontier Foundation

Ann Arbor, Michigan 48104 1550 Bryant Street, Suite 725

San Francisco, California 94103

____________________________