STIPULATION AND [PROPOSED] ORDER REGARDING DEFENDANTS' FORUM MOTION BRIEFING SCHEDULE

LUCY H. KOH, Judge.

WHEREAS, on September 27, 2011, Plaintiff filed the instant shareholder derivative complaint ("Complaint") in the above-captioned action;

WHEREAS, nominal defendant Juniper Networks, Inc. and defendants Kevin Johnson, Scott Kriens, Pradeep Sindhu, Robert M. Calderoni, Mary B. Cranston, John Michael Lawrie, Stratton Sclavos, William R. Stensrud, William Meehan, David Schlotterbeck, and Mercedes Johnson (collectively, "Defendants") waived service of a summons upon them on or about October 7, 2011, such that their response(s) to the Complaint are currently due on or about December 6, 2011;

WHEREAS, Plaintiff's counsel agreed to give Defendants an extension of time within which to respond to the Complaint;

WHEREAS, four similar consolidated shareholder derivative lawsuits are concurrently proceeding in the Superior Court in and for Santa Clara County, California, titled In re Juniper Networks, Inc. Shareholder Derivative Litigation, Lead Case No. 111CV-207701 (Consolidated with Case Nos. 111CV-208042, 111CV-208566, 111CV-208916);

WHEREAS, Defendants intend to file a motion in both this action and in the consolidated actions in the Santa Clara Superior Court requesting that all the similar shareholder derivative lawsuits against them proceed in a single forum (the "Forum Motion");

WHEREAS, counsel for Defendants and counsel for Plaintiff have met and conferred regarding the orderly and efficient management of this case and have agreed in principle that, in order to conserve the resources of the parties and the Court, Defendants' Forum Motion should be heard and decided before Defendants' motion(s) to dismiss the Complaint under Rules 12 or 23.1 of the Federal Rules of Civil Procedure, and that Defendants may file their anticipated Forum Motion without waiving their rights to thereafter file any motion(s) to dismiss the Complaint under any other grounds, including those set forth in Rules 12 and 23.1 of the Federal Rules of Civil Procedure;

WHEREAS, counsel for Defendants and counsel for Plaintiff have met and conferred and agreed on a briefing schedule for Defendants' Forum Motion, and have also agreed to be prepared to discuss the timing of Defendants' motion(s) to dismiss the Complaint at the upcoming Case Management Conference on January 12, 2012;

NOW, THEREFORE, the parties, by and through their undersigned counsel, hereby agree and stipulate to the following:

(1) Defendants shall file their Forum Motion on or before December 16, 2011;

(2) Plaintiff shall file her opposition to the Forum Motion on January 13, 2012;

(3) Defendants shall file their reply to the Forum Motion on January 20, 2012;

(4) The hearing on Defendants' Forum Motion will be held on March 22, 2012 at 1:30 p.m.;

(5) By filing their Forum Motion, Defendants will not waive their rights to thereafter file any motion(s) to dismiss the Complaint on any other the grounds, including any and all bases set forth in Rules 12 and 23.1 of the Federal Rules of Civil Procedure; and

(6) The parties will be prepared to discuss the timing of Defendants' motion to dismiss at the Case Management Conference on January 12, 2012.

SO STIPULATED.

[PROPOSED] ORDER

Good cause appearing, it is hereby ORDERED:

(1) Defendants shall file their Forum Motion on or before December 16, 2011;

(2) Plaintiff shall file her opposition to the Forum Motion on January 13, 2012;

(3) Defendants shall file their reply to the Forum Motion on January 20, 2012;

(4) The hearing on Defendants' Forum Motion will be held on March 22, 2012 at 1:30 p.m.;

(5) By filing their Forum Motion, Defendants will not waive their rights to thereafter file any motion(s) to dismiss the Complaint on any other the grounds, including any and all bases set forth in Rules 12 and 23.1 of the Federal Rules of Civil Procedure; and

(6) The parties will be prepared to discuss the timing of Defendants' motion to dismiss at the Case Management Conference on January 12, 2012.

PURSUANT TO STIPULATION, IT IS SO ORDERED.