STIPULATION TO EXTEND TIME TO RESPOND

(Civil L.R. 6-1(a))

JOSEPH C. SPERO, District Judge.

WHEREAS, on May 16, 2016 and May 18, 2016, respectively, two putative class action complaints were filed in this Court against LendingClub Corporation ("LendingClub"), Renaud Laplanche and Carrie L. Dolan: Evellard v. LendingClub, et al., 16-CV-2627-WHA, and Wertz v. LendingClub, et al., 16-CV-2670-WHA (together, the "Class Actions");

WHEREAS, on June 6, 2016, plaintiff in the above-captioned action ("Plaintiff") filed a putative derivative action ("Derivative Action") against defendants Renaud Laplanche, Carrie L. Dolan, Scott Sanborn, Daniel T. Ciporin, Jeffrey Crowe, Rebecca Lynn, John J. Mack, Mary Meeker, John C. Morris, Lawrence H. Summers, Simon Williams, and Nominal Defendant LendingClub (collectively, "Defendants," and with Plaintiff, the "Parties");

WHEREAS, on July 14, 2016, the parties in the Class Actions and Derivative Action entered into a Stipulation and [Proposed] Order to Relate Cases based on their belief that these actions are "related cases" within the meaning of Civil Local Rule 3-12;

WHEREAS, the current deadline for defendants Carrie L. Dolan, Scott Sanborn, Daniel T. Ciporin, Jeffrey Crowe, Rebecca Lynn, John J. Mack, Mary Meeker, John C. Morris, Lawrence H. Summers, Simon Williams, and Nominal Defendant LendingClub to move, answer or otherwise respond to the complaint in the Derivative Action is August 12, 2016;

WHEREAS, the current deadline for defendant Renaud Laplanche to move, answer or otherwise respond to the complaint in the Derivative Action is August 15, 2016;

WHEREAS, a hearing on motions to be appointed lead plaintiff in the related Class Actions has been set for August 15, 2016;

WHEREAS, it is anticipated that the party appointed lead plaintiff in the related Class Actions will file a consolidated complaint pursuant to a schedule set by the Court;

WHEREAS, Plaintiff has agreed that no later than 30 days after the filing of the consolidated complaint in the related Class Actions, he will either file an amended derivative complaint or notify Defendants of his intention to proceed with the existing complaint; and

WHEREAS, the Parties have agreed that (a) no later than 30 days after Plaintiff has either filed an amended derivative complaint or notified Defendants of his intention to proceed with the existing complaint, LendingClub will file a motion to dismiss the Derivative Action for failure to allege demand futility ("Demand Futility Motion"), and (b) none of the Defendants need to respond to the operative complaint pending resolution of the Demand Futility Motion.

IT IS ACCORDINGLY STIPULATED, pursuant to Civil L.R. 6-1(a), by and between the undersigned counsel for the parties, that:

ATTESTATION (CIVIL LOCAL RULE 5-1(i)(3))

In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this document has been obtained from the signatory.