STIPULATION AND [PROPOSED] SCHEDULING ORDER

EDWARD M. CHEN, District Judge.

Pursuant to Civil Local Rule 7-12, the parties, lead plaintiff KBC Asset Management NV ("KBC" or "Lead Plaintiff") and defendants LeapFrog Enterprises, Inc. ("LeapFrog" or the "Company"), John Barbour and Raymond L. Arthur (collectively, "Defendants"), by and through their undersigned counsel of record, submit the following stipulation and proposed order:

WHEREAS, on May 1, 2015, the Court held a hearing on motions to appoint Lead Plaintiff and Lead Counsel and motion to consolidate cases. Dkt. No. 41;

WHEREAS, on May 5, 2015, the Court issued a written order granting KBC's motion for appointment as Lead Plaintiff and approved its selection of Motley Rice LLC ("Motley Rice") and Robbins Geller Rudman & Dowd LLP ("Robbins Geller") as Co-Lead Counsel. Dkt. No. 43. The Court also ordered the consolidation of Grayson v. LeapFrog, Case No. 3:15-cv-00453 and Farias v. LeapFrog, Case No. 3:15-cv-00478 with Newett v. LeapFrog, Case No. 3:15-cv-00347. Id.;

WHEREAS, during the May 1, 2015 hearing, the Court ordered that a Consolidated Complaint shall be filed by June 24, 2015, and that Defendants be afforded approximately five weeks to respond to said complaint. The Court also scheduled the hearing on Defendants' anticipated motion to dismiss and a case management conference ("CMC") for September 24, 2015. Dkt. No. 41;

WHEREAS, the parties have met and conferred and agreed given the parties' schedule and the complexity of this securities action, that approximately 30 days should be afforded to oppose any motion to dismiss and 30 days to be afforded to any reply. Consequently, the parties respectfully request that the hearing date and CMC previously scheduled for September 24, 2015 be rescheduled to October 8, 2015 at 1:30 p.m., or a date convenient for the Court thereafter;

NOW THEREFORE, the parties hereby agree and stipulate to the following deadlines:

1. Lead Plaintiff shall file a consolidated complaint no later than June 24, 2015;

2. Defendants' response to the amended complaint shall be filed on or before July 24, 2015;

3. Lead Plaintiff's opposition to Defendants' response shall be filed on or before August 25, 2015;

4. Defendants' reply shall be filed on or before September 22, 2015; and

5. The hearing on Defendants' anticipated motion to dismiss and CMC shall be moved from September 24, 2015 to October 8, 2015 at 1:30 p.m.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.