JOINT STIPULATION AND [PROPOSED] ORDER TO SET BRIEFING SCHEDULE

JON S. TIGAR, District Judge.

WHEREAS, on January 5, 2017, the Court held a hearing on Plaintiff Union Asset Management Holding AG's ("Union" or "Lead Plaintiff') motion to consolidate the above captioned action to appoint Union as Lead Plaintiff, and to approve Union's selection of counsel for the class (Dkt. No. 29) (the "Lead Plaintiff Motion");

WHEREAS, on January 5, 2017, the Court granted the Lead Plaintiff Motion (Dkt. No. 58);

WHEREAS, on November 21, 2016, the Court entered the parties' Joint Stipulation and [Proposed] Order to Enlarge Time to Respond to Complaint (Dkt. No. 23), which extended the time in which defendants Wells Fargo & Company, John G. Stumpf, John R. Shrewsberry, and Carrie Tolstedt (together, the "Original Defendants") could respond to any complaint in this action until 60 days after Lead Plaintiff filed a consolidated class action complaint;

WHEREAS, on January 11, 2017, the Lead Plaintiff and the Original Defendants (together, the "Original Parties") filed a Joint Stipulation and [Proposed] Order to Continue Case Management Conference and Set Briefing Schedule (Dkt. No. 63) (the "Initial Joint Stipulation");

WHEREAS, on January 11, 2017, the Court entered the Initial Joint Stipulation (Dkt. No. 64), pursuant to which the Lead Plaintiff was to file a consolidated class action complaint on or before March 6, 2017; the Original Defendants are to respond to the consolidated class action complaint, by filing motions to dismiss or otherwise, on or before May 5, 2017; Lead Plaintiff is to file oppositions to the Original Defendants' motions to dismiss, if any, on or before July 7, 2017; and the Original Defendants are to file replies in support of their motions to dismiss, if any, on or before August 11, 2017;

WHEREAS, on March 6, 2017, Lead Plaintiff and individual plaintiffs Gary Hefler, Marcelo Mizuki, and Guy Solomonov (together, "Plaintiffs") filed a Consolidated Class Action Complaint for Violations of the Federal Securities Laws (the "Consolidated Complaint") (Dkt. No. 72);

WHEREAS, the Consolidated Complaint for the first time asserts claims against 21 new defendants who were not previously parties to this action: (1) Timothy J. Sloan, (2) David M. Carroll, (3) David Julian, (4) Hope A. Hardison, (5) Michael J. Loughlin, (6) Avid Modjtabai, (7) James M. Strother, (8) John D. Baker II, (9) JohnS. Chen, (10) Lloyd H. Dean, (11) Elizabeth A. Duke, (12) Susan E. Engel, (13) Enrique Hernandez Jr., (14) Donald M. James, (15) Cynthia H. Milligan, (16) Federico F. Pefta, (17) James H. Quigley, (18) Judith M. Runstad, (19) Stephen W. Sanger, (20) Susan G. Swenson, and (21) Suzanne M. Vautrinot (together, the "New Defendants");

WHEREAS, the New Defendants were not previously parties to this action and many of them have only recently retained counsel for this action;

WHEREAS, counsel for Plaintiffs, the Original Defendants, and the New Defendants have met and conferred and, in light of the large number ofNew Defendants and in order to coordinate all briefing on the same schedule, have agreed to a revised briefing schedule for the Original Defendants' and New Defendants' (together, "Defendants") forthcoming motions to dismiss the Consolidated Class Action Complaint;

WHEREAS, the parties agree that nothing in this Stipulation will be construed as a waiver of any of Defendants' or Plaintiffs rights or positions in law or in equity;

NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, between Plaintiffs, by and through their counsel, and Defendants, by and through their counsel, that:

ATTESTATION PURSUANT TO GENERAL ORDER 45

I, Brendan P. Cullen, in compliance with General Order 45, Section X(B), hereby attest that I obtained the concurrence of all of the above-listed counsel in filing this document.

[PROPOSED] ORDER

THE FOREGOING STIPULATION IS APPROVED AND IT IS SO ORDERED.