STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND AND CONTINUING CASE MANAGEMENTCONFERENCE

SAUNDRA B. ARMSTRONG, District Judge.

WHEREAS, Plaintiff Mark Leevan filed a Complaint against Defendants Credit Suisse International and Credit Suisse Securities (USA) LLC on June 17, 2013 (the "Action");

WHEREAS, Defendant Credit Suisse Securities (USA) LLC was served with the summons and complaint on July 17, 2013;

WHEREAS, the undersigned parties anticipate that additional complaints may be filed, and a Lead Plaintiff and Lead Counsel will need to be appointed;

WHEREAS, the case management conference is currently scheduled before this Court on September 18, 2013 at 2:30 PM;

NOW, THEREFORE, in the interest of judicial economy and good cause showing, the parties, by and through their undersigned counsel of record, hereby agree and stipulate, and the Court hereby orders, as follows:

(1) Defendants need not respond to the complaint filed on June 17, 2013;

(2) After the appointment of a Lead Plaintiff and Lead Counsel, Defendants and Lead Plaintiff shall meet and confer to determine a schedule for the filing of an amended complaint, and Defendants' response thereto. The parties will file a stipulated schedule for approval by the Court; and

(3) The case management conference currently scheduled for September 28, 2013 at 2:30 PM shall be continued until January 16, 2013 at 3:00 PM, with the other dates set by the Order Setting Initial Case Management Conference and ADR Deadlines continued accordingly; and

(4) No party is waiving any rights, claims, or defenses of any kind except as expressly stated herein. The parties respectfully request that the Court enter an Order approving this Stipulation.

IT IS SO STIPULATED.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.