STIPULATION AND [PROPOSED] ORDER SETTING DATE FOR AMENDED COMPLAINT

SUSAN ILLSTON, District Judge.

WHEREAS, between May 25, 2011 and June 21, 2011, six shareholder derivative actions were filed on behalf of Wells Fargo & Company, naming various individual and entity defendants.

WHEREAS, on August 3, 2011, the Court issued an Order Granting Unopposed Motions to Consolidate Related Actions; Appointing Co-Lead Plaintiffs and Co-Lead Counsel, and ordered plaintiffs to file a master complaint for the consolidated cases by August 19, 2011.

WHEREAS, on August 9, 2011, counsel for plaintiff in one of the consolidated actions, Cottrell v. Stumpf, No. 11-cv-3006-SI, filed a Request for Voluntary Dismissal of Cottrell Action pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii). Said request was granted by Order of the court entered on August 12, 2011.

WHEREAS, on August 15, 2011, counsel for plaintiff, in another of the consolidated actions, IBEW Local Union 98 and Louisiana Municipal Police Employees Retirement System v. Stumpf, No. 11-CV-2662-SI, filed a Request of Plaintiffs Louisiana Municipal Police Employees Retirement System and IBEW Local Union 98 for Voluntary Dismissal of LAMPERS Action Pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i).

WHEREAS, on August 15, 2011, counsel for plaintiff in consolidated action Gorberg v. Stumpf, No. 11-CV-2577-SI, filed a Request for Voluntary Dismissal of Gorberg Action pursuant to Fed. R. Civ. P. 4(a)(1)(A)(i).

WHEREAS, the parties, through their counsel, have met and conferred regarding the scope of the current allegations and agreed to setting the date for filing of a consolidated complaint.

NOW THEREFORE, the undersigned parties, by and through their counsel of record, stipulate as follows subject to the approval of the Court:

Lead Plaintiffs shall file and serve a Consolidated Complaint no later than September 12, 2011.

I, Shawn Williams, am the ECF User whose ID and password are being used to file this Stipulation and [Proposed] Order Setting Date for Amended Complaint and Setting Briefing Schedule for Motion to Dismiss. In compliance with General Order 45, X.B., I hereby attest that Sarah A. Good and Kent M. Roger have concurred in this filing.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

CERTIFICATE OF SERVICE

I hereby certify that on August 19, 2011, I authorized the electronic filing of the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the e-mail addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I caused to be mailed the foregoing document or paper via the United States Postal Service to the non-CM/ECF participants indicated on the attached Manual Notice List.

I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on August 19, 2011.

MAILING INFORMATION FOR A CASE 3:11-cv-02369-SI

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