STIPULATION AND ORDER EXTENDING TIME FOR DEFENDANTS TO RESPOND TO THE COMPLAINTS

WILLIAM H. ORRICK, District Judge.

Plaintiff Juan M. Rodriguez Beltran, individually and on behalf of all others similarly situated, and Plaintiff Pyramid Holdings, Inc., individually and on behalf of all others similarly situated, by through their undersigned counsel, ("Plaintiffs"), and Defendants TerraForm Global, Inc., SunEdison, Inc., Ahmad Chatila, Carlos Domenech Zornoza, Jeremy Avenier, Martin Truong, Brian Wuebbels, J.P. Morgan Securities LLC., Barclays Capital Inc., Citigroup Global Markets Inc Morgan Stanley & Co. LLC, Goldman, Sachs & Co., Merrill Lynch, Pierce, Fenner & Smith Incorporated, Deutsche Bank Securities Inc., BTG Pactual US Capital LLC, Itaú BBA Securities, Inc., SMBC Nikko Securities America, Inc., SG Americas Securities, LLC, and Kotak Mahindra, Inc. ("Defendants"), by and through their undersigned counsel, hereby stipulate and agree as follows:

WHEREAS, on October 29, 2015, Juan M. Rodriguez Beltran, individually and on behalf of all others similarly situated, filed a class action complaint captioned Beltran v. TerraForm Global et al., Case No. 3:15-cv-04981-WHO (the "Beltran Action") against the Defendants alleging violations of the federal securities laws;

WHEREAS, on October 29, 2015, pursuant to 15 U.S.C. § 77z-1(a)(3)(A)(i), Plaintiff Beltran caused a notice to be published on Businesswire, a "widely circulated national business-oriented wire service," advising members of the purported class of, inter alia: (1) the pendency of the action; (2) the claims asserted therein; (3) the purported class period; and (4) that, not later than 60 days after the date on which the notice was published, any member of the purported class had the right to move the Court to serve as Lead Plaintiff of the class;

WHEREAS, on November 5, 2015, Pyramid Holdings, Inc., individually and on behalf of all others similarly situated, filed a class action complaint captioned Pyramid Holdings v. TerraForm Global, Inc. et al., 3:15-cv-05068-RS (the "Pyramid Holdings Action") against the Defendants alleging violations of the federal securities laws;

WHEREAS, the Beltran Action and the Pyramid Holdings Action are class actions brought against the same defendants, alleging the same violations of federal securities law in connection with TerraForm Global's IPO, and proceeding before different judges would likely lead to an unduly burdensome duplication of labor and expense, and cause the potential for conflicting results;

WHEREAS, the parties recognize that pursuant to Civil Local Rule 3-12, these actions are related and should be so marked, and agree that Defendants will prepare the appropriate Joint Administrative Motion to Consider Whether Cases Should be Related;

WHEREAS, the Court in the Beltran Action and the Pyramid Holdings Action has issued Scheduling Orders which set certain different deadlines, including for ADR filings, Initial Case Management Conferences, and Initial Disclosures in each case;

WHEREAS, pursuant to 15 U.S.C. § 77z-1(a)(3)(B) the Court must appoint a Lead Plaintiff;

WHEREAS, on December 28, 2015 certain class members moved for appointment as Lead Plaintiff and lead counsel;

WHEREAS, the parties agree that, in light of the pending motions for appointment as Lead Plaintiff and lead counsel, and in the interests of judicial economy and the preservation of the Court's and the parties' resources, Defendants need not respond to the pending Complaints;

WHEREAS, the parties agree that, in light of the pending motions for appointment as Lead Plaintiff and lead counsel and the anticipated Administrative Motion to Consider Whether Cases Should be Related, and in the interests of judicial economy and the preservation of the Court's and the parties' resources, the deadlines set in the Scheduling Orders should be vacated and new dates set after the cases are related and consolidated;

NOW, THEREFORE, it is hereby stipulated as follows:

PURSUANT TO STIPULATION, IT IS SO ORDERED.