JOINT STIPULATION AND [PROPOSED] ORDER TO ENLARGE TIME TO RESPOND TO COMPLAINT

JON S. TIGAR, District Judge.

WHEREAS on September 26, 2016, Gary Hefler, individually and on behalf of all others similarly situated, filed a putative Class Action Complaint For Violations Of the Federal Securities Laws (the "Hefler Complaint") against Wells Fargo & Company ("Wells Fargo"), John G. Stumpf, John R. Shrewsberry, and Carrie L. Tolstedt (collectively, "Defendants");

WHEREAS on September 28, 2016, Steve Klein, individually and on behalf of all others similarly situated, filed a putative Class Action Complaint For Violations Of the Federal Securities Laws (the "Klein Complaint") against Defendants;

WHEREAS Gary Hefler and Steve Klein (together, "Plaintiffs") and Defendants anticipate that the above-captioned cases will be consolidated, that a lead plaintiff and lead counsel will be appointed by the Court, and that a Consolidated Class Action Complaint will be filed thereafter;

WHEREAS Plaintiffs and Defendants have agreed to extend the time in which Defendants may respond to Plaintiffs' complaint until 60 days following the filing of a Consolidated Class Action Complaint;

WHEREAS no prior extensions have been granted for the time in which Defendants could respond to the Hefler Complaint or the Klein 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:

1. Defendants' time to respond to the complaints in the above-captioned actions is hereby extended for 60 days following the filing of a Consolidated Class Action Complaint.

2. In submitting this Stipulation, Defendants and Plaintiffs do not waive any of their rights or positions in law or in equity, and Defendants do not waive any objection or defense they may raise to the Court's personal jurisdictional over them or to the propriety of venue in this case.

IT IS SO STIPULATED.

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.

ORDER

THE FOREGOING STIPULATION IS APPROVED AND IT IS SO ORDERED.