STIPULATION AND ORDER REGARDING THE PAGE LIMITATION FOR LEAD PLAINTIFFS' OMNIBUS OPPOSITION TO DEFENDANTS' MOTIONS TO DISMISS

HAYWOOD S. GILLIAM, Jr., District Judge.

WHEREAS, this action for violations of the federal securities laws was filed against defendants Solazyme, Inc., Jonathan S. Wolfson, Tyler W. Painter, David C. Cole, Jerry Fiddler, Michael V. Arbige, Ian T. Clark, Peter Kovacs, James R. Craigie, ("Solazyme Defendants") Goldman, Sachs & Co., and Morgan Stanley & Co. LLC ("Underwriter Defendants"), (collectively "Defendants");

WHEREAS, on October 8, 2015, the Court entered an order appointing plaintiffs John Medlin, John Hussain, Norfolk County Retirement System, Nancy Ackels, and Leonardo Fernandez as lead plaintiffs ("Lead Plaintiffs");

WHEREAS, on November 9, 2015, the Court entered a scheduling order that provided that Lead Plaintiffs were to file a consolidated complaint no later than December 15, 2015, Defendants were to file a response to the complaint no later than February 12, 2016, Lead Plaintiffs were to file any opposition to Defendants' response no later than March 25, 2016, and Defendants were to file any reply no later than April 22, 2016;

WHEREAS, on December 15, 2015, Lead Plaintiffs filed their Consolidated Class Action Complaint for Violations of the Federal Securities Laws ("Consolidated Complaint");

WHEREAS, on February 12, 2016, the Solazyme Defendants and the Underwriter Defendants filed separate briefs moving to dismiss the Consolidated Complaint;

WHEREAS, the motion to dismiss filed by the Solazyme Defendants is 25-pages in length and the motion to dismiss filed by the Underwriter Defendants is 14-pages in length;

WHEREAS, Lead Plaintiffs intend to file an omnibus opposition to both motions to dismiss for purposes of efficiency and to avoid the repetition of argument;

WHEREAS, Lead Plaintiffs believe that the 25-page limitation of Local Rule 7-3 will not afford Lead Plaintiffs sufficient opportunity to respond to the arguments contained within both motions to dismiss;

WHEREAS, counsel for the parties have met and conferred, and counsel for Defendants do not oppose a page limitation of 35 pages for Lead Plaintiffs' omnibus opposition to Defendants' motions to dismiss;

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

1. Lead Plaintiffs shall have up to, and including, 35-pages for their omnibus opposition to Defendants' motions to dismiss.

ORDER

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.