Plastic2Oil Inc (PTOI)

[P2O I'm from MO]

STIPULATION TO EXTEND DISCOVERY DEADLINES

Plaintiff Securities and Exchange Commission (“Commission”) and Defendant Ronald Baldwin, Jr. (“Defendant”) hereby stipulate, subject to approval by the Court, as follows:

1. This is a complex case alleging securities and accounting fraud by stating materially false and inaccurate financial information on the financial statements of JBI, Inc. (“JBI”) for two reporting periods during 2009. Specifically, the Commission has alleged that the Defendant and others misrepresented and overstated the actual value of JBI’s assets and, hence, of the company itself by almost 1,000%, using the overvalued financial statements in two private capital raising efforts that raised more than $8.4 million from investors.

2. During a status conference held on May 13, 2013, the Court allowed counsel for the parties 30 days to reach a settlement-in-principle, otherwise automatic disclosures must be served by June 13, 2013, followed by additional discovery deadlines. (ECF No. 33.)

3. On May 29, 2013, the Commission staff and the Defendant agreed in principle to settle this case in its entirety.

4. Based on the settlement-in-principle, the parties agree to stay automatic disclosures, fact discovery, and expert discovery deadlines until December 20, 2013.

5. The extension of discovery deadlines will permit the Commission time to review and either approve or reject the proposed settlement.