STIPULATION AND [PROPOSED] ORDER CONTINUING THE CASE MANAGEMENT CONFERENCE

CLAUDIA WILKEN, District Judge.

Plaintiffs and the Defendants in this action hereby stipulate as follows:

WHEREAS, on March 25, 2014, Plaintiff Bradley Cooper filed a Motion to Appoint Lead Plaintiff and Lead Counsel (Dkt. 11);

WHEREAS, all oppositions to lead plaintiff motions are due on April 8, 2014, and all replies to motions for lead plaintiff are due on April 15, 2014 (Dkt. 11);

WHEREAS, the hearing on Plaintiffs' Motions for Lead Plaintiff is scheduled for May 15, 2014;

WHEREAS, on January 27, 2014, the Court set a Case Management Conference to be conducted on April 23, 2014, ordering the parties to submit a Case Management Statement by April 16, 2014 (Dkt. 5);

WHEREAS, this matter is a class action under the federal securities laws and subject to the Private Securities Litigation Reform Act of 1995 (PSLRA);

WHEREAS, pursuant to the Court's direction, the Plaintiffs will file a Consolidated Amended Complaint after the Court appoints a Lead Plaintiff and Lead Counsel;

WHEREAS, pursuant to the PSLRA, all discovery in this case is stayed until the Court rules on the sufficiency of the Consolidated Amended Complaint (15 U.S.C. §78u-4(b)(3)(B));

WHEREAS, the parties agree and respectfully submit that a case management conference would be premature and not benefit the Court or the parties at this time because discovery is stayed;

NOW, THEREFORE, the parties jointly request that the Court take the Case Management Conference off calendar and that it be rescheduled, if necessary, after the discovery stay is lifted, and further, the Case Management Statement due on April 16, 2014, be deferred until one week prior to any Case Management Conference that may be scheduled.

IT IS SO STIPULATED.

ORDER

Pursuant to the stipulation of the parties, the April 23, 2014 Case Management Conference is hereby taken off-calendar, to be rescheduled, if necessary, following the lifting of the discovery stay. No Case Management Statement is currently due.

IT IS SO ORDERED.