STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS (PRETRIAL SCHEDULING) CONFERENCE

GARLAND E. BURRELL, Jr., District Judge.

1. WHEREAS, on June 6, 2011 the Court issued an Order setting a Status (Pretrial Scheduling) Conference for November 14, 2011.

2. WHEREAS, on October 3, 2011 Plaintiff filed its Second Amended Complaint in this action which includes claims under the federal securities laws.

3. WHEREAS, certain Specially Appearing Defendants, after review of the Second Amended Complaint, have determined that they will file a motion (or motions) to dismiss the Second Amended Complaint on various grounds and said motions shall be scheduled for hearing on December 19, 2011,

4. WHEREAS, the parties have agreed that Specially Appearing Defendants' motions may be filed and served on or before November 14, 2011.

5. WHEREAS, under PLSRA (15 U.S.C. § 78u-4(b)(3)) "all discovery and other proceedings" in this matter are stayed pending resolution of Specially Appearing Defendants' motions to dismiss.

6. WHEREAS, Plaintiff and Specially Appearing Defendants respectfully submit that, in light of the PLSRA stay, the Court should defer consideration of all discovery and litigation deadlines until the issues identified in the motions to dismiss have been addressed by the Court, such that the case is either dismissed, or, alternatively, the pleadings resolved and the case is at issue and that a continuance of the Status (Pretrial Scheduling) Conference by approximately another sixty (60) days will conserve the resources of the parties and the Court and promote judicial economy by allowing time for the Court to address the motions to dismiss.

NOW, THEREFORE, Plaintiff and Specially Appearing Defendants, by and through their respective counsel of record, hereby stipulate as follows:

1. That the Status (Pretrial Scheduling) Conference, presently set for November 14, 2011, be continued approximately 60 days to January 16, 2012.

IT IS SO STIPULATED.

ORDER

The Status (Pretrial Scheduling) Conference, presently set for November 14, 2011, is continued to January 30, 2012, at 9:00 a.m. A joint status report shall be filed fourteen days prior to the hearing.