STIPULATION AND [PROPOSED] ORDER REGARDING CONTINUING INITIAL CASE MANAGEMENT CONFERENCE

EDWARD M. CHEN, District Judge.

Lead Plaintiff Boilermaker Blacksmith National Pension Trust, by and through its respective counsel ("Plaintiff"), and defendants Impax Laboratories, Inc., Larry Hsu, and Arthur A. Koch, by and through their respective counsel, (collectively, "Defendants"), hereby stipulate to the following:

WHEREAS, on March 7, 2013, Plaintiff Denis Mulligan, individually and on behalf of all others similarly situated, filed a complaint captioned Denis Mulligan v. Impax Laboratories, Inc. et al., No. 13-cv-01037, a putative class action under the Private Securities Litigation Reform Act of 1995 (the "PSLRA") alleging securities fraud (the "Mulligan matter");

WHEREAS, pursuant to the March 7, 2013 Case Management Conference Order, the Initial Case Management Conference for the Mulligan matter was initially scheduled for June 6, 2013;

WHEREAS, on April 8, 2013, Plaintiff Haverhill Retirement Center, individually and on behalf of all others similarly situated, filed a complaint captioned Haverhill Retirement System v. Impax Laboratories, Inc. et al., No. 13-cv-01566, also a putative class action under the PSLRA alleging securities fraud (the "Haverhill matter").

WHEREAS, pursuant to the April 8, 2013 Case Management Conference Order, the Initial Case Management Conference for the Haverhill matter was initially scheduled for July 12, 2013;

WHEREAS, on April 19, 2013, and April 22, 2013, Plaintiffs Haverhill and Mulligan, respectively, stipulated with Defendants to continue the Initial Case Management Conferences in their respective matters until after the Defendants filed an answer, which would follow any ruling on Defendants' motion to dismiss (the Mulligan matter, Dkt. #15 ¶ 9; the Haverhill matter, Dkt. #16 ¶ 9);

WHEREAS, pursuant to those stipulations, on April 25, 2013, the Court reset the respective Initial Case Management Conferences for November 7, 2013 (the Mulligan matter, Dkt. #15; the Haverhill matter, Dkt. #16);

WHEREAS, on July 2, 2013, the Court consolidated the Mulligan and Haverhill matters and appointed Boilermaker Blacksmith National Pension Trust as Lead Plaintiff (Dkt. #53);

WHEREAS, on August 27, 2013, Lead Plaintiff and Defendants stipulated, and the Court ordered pursuant to such stipulation on August 28, 2013, for Defendants' motion to dismiss to be filed on or before November 14, 2013 (Dkt. #62);

WHEREAS, in order to avoid the unnecessary expenditure of the Court's and parties' resources prior to the filing of and ruling on Defendants' motion to dismiss, the parties agreed and the Court set the Initial Case Management Conference for April 17, 2014 (Dkt. #80).

WHEREAS the Court reset the Initial Case Management Conference from April 17, 2014 to April 15, 2014 (Dkt. #83);

WHEREAS, Lead Counsel for Defendants has a previous engagement outside the State of California on April 15, 2014;

WHEREAS, the parties agreed that April 24, 2014, at 9:00 a.m. is a mutually convenient date for the Case Management Conference;

WHEREAS, this Stipulation and Order is without prejudice to, or waiver of, any rights, arguments, or defenses otherwise available to the parties to this action.

NOW THEREFORE, the undersigned parties, by and through their counsel of record, stipulate as follows:

The Initial Case Management Conference, currently scheduled for April 15, 2014 is continued to April 24, 2014, at 9:00 a.m.

PURSUANT TO STIPULATION, IT IS SO ORDERED.