STIPULATION AND [PROPOSED] ORDER REGARDING SCHEDULING

SAMUEL CONTI, District Judge.

WHEREAS, the Indirect Purchaser Plaintiffs ("IPPs"), the Direct Action Plaintiffs ("DAPs"), the California Attorney General,1 and the undersigned Defendants2 agree that a modest modification of the case schedule will ultimately aid in the efficient resolution of the litigation;

IT IS HEREBY STIPULATED AND AGREED by and between counsel for the IPPs, counsel for the DAPs, and counsel for the undersigned Defendants in the above-captioned actions as follows:

SCHEDULE

April 15, 2014 Last day for IPPs, DAPs and the California Attorney General to serve opening expert reports on the merits; last day for Defendants to serve opening expert reports on affirmative defenses;

July 3, 2014 For any depositions noticed, but not yet taken, by April 15, 2014, the Parties may supplement their opening reports to the extent that the supplements are limited to evidence that is elicited during such depositions;

August 5, 2014 Last day for Defendants to serve opposition expert reports on the merits; last day for IPPs, DAPs and California Attorney General to serve opposition expert reports on affirmative defenses;

September 5, 2014 Close of fact discovery;

September 23, 2014 Last day for IPPs, DAPs and California Attorney General to serve rebuttal expert reports on the merits; last day for Defendants to serve rebuttal expert reports on affirmative defenses;

October 31, 2014 Last day for Defendants to serve sur-rebuttal expert reports on the merits; last day for IPPs, DAPs and California Attorney General to serve sur-rebuttal expert reports on affirmative defenses;

November 7, 2014 Last day to file dispositive motions;

December 5, 2014 Last day to file pre-trial Daubert motions (parties may decide to reserve these motions for trial if they desire to do so);

December 5, 2014* Plaintiffs' exchange of trial exhibits, deposition excerpts, and witness lists (with objections, including objections to translations);

December 23, 2014 Last day to file oppositions to dispositive motions;

January 9, 2015* First simultaneous exchange of jury instructions and special verdict forms;

January 16, 2015 Last day to file oppositions to pre-trial Daubert motions;

January 23, 2015 Last day to file replies in support of dispositive motions;

January 23, 2015* Last day for filing motions in limine and other non-dispositive pre-trial motions;

January 26, 2015* Second simultaneous exchange of jury instructions and special verdict forms;

January 29, 2015* Defendants' exchange of trial exhibits, deposition excerpts, and witness lists (with objections, including objections to translations);

January 30, 2015* Last day to meet and confer re pre-trial order;

February 6, 2015* Last day for parties to exchange proposed exhibits and witness lists; file pretrial order, agreed set of jury instructions, and verdict forms

February 9, 2015 Last day to file replies in support of pre-trial Daubert motions;

February 13, 2015* Last day for filing oppositions to motions in limine and other non-dispositive pre-trial motions;

February 20, 2015* Last day for filing replies in support of motions in limine and other non-dispositive pre-trial motions;

February 27, 2015* Hearing on motions in limine and other non-dispositive pre-trial motions, and final pre-trial conference;

March 9, 2015* Trial(s).

* All deadlines marked with an asterisk do not apply to those actions that were filed outside of the N.D. Cal. and, following the Court's rulings on dispositive motions and Daubert motions, those actions will be returned to the courts in which they were originally filed.

All parties reserve the right to seek modification of the schedule based on the number of expert reports and the number of motions which will be filed, both of which are presently unknown.

* * *

The undersigned parties jointly and respectfully request that the Court enter this stipulation as an order.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Pursuant to Local Rule 5-1(i), the filer attests that the concurrence in the filing of this document has been obtained from each of the above signatories.