STIPULATION AND [PROPOSED] ORDER SETTING BRIEFING AND HEARING SCHEDULE FOR INDIVIDUAL DEFENDANTS' MOTION TO DISMISS AND CONTINUING CASE MANAGEMENT CONFERENCE

SUSAN ILLSTON, District Judge.

Defendants John G. Stumpf, Howard I. Atkins, John D. Baker II, John S. Chen, Lloyd H. Dean, Susan E. Engel, Enrique Hernandez, Jr., Donald M. James, Richard D. McCormick, Mackey J. McDonald, Cynthia H. Milligan, Nicholas G. Moore, Philip J. Quigley, Judith M. Runstad, Stephen W. Sanger and Susan G. Swenson (collectively, "Individual Defendants"), and plaintiffs Pirelli Armstrong Tire Corporation Retiree Medical Benefits Trust and City of Westland Police and Fire Retirement System (collectively, "Plaintiffs") hereby stipulate to the following:

WHEREAS, on August 3, 2011, the Court granted the unopposed motions to consolidate the related actions, appointed Robbins, Geller, Rudman & Dowd LLP and Barrett Johnston, LLC as Plaintiffs' co-lead counsel and ordered Plaintiffs to file a master complaint for the consolidated cases by August 19, 2011;

WHEREAS, on August 25, 2011, the Court granted the parties' stipulation and proposed order setting September 12, 2011 as the new filing deadline for the master complaint for the consolidated cases;

WHEREAS, on September 12, 2011, Plaintiffs filed a "Verified Consolidated Shareholder Derivative Complaint For Breach of Fiduciary Duty, Abuse of Control, Gross Mismanagement and Corporate Waste" (the "Consolidated Complaint");

WHEREAS, the Individual Defendants (except for a new defendant, Howard I. Atkins, who accepts service of the Consolidated Complaint by entering into this stipulation) have until September 29, 2011 to respond to the Consolidated Complaint and all of the Individual Defendants intend to respond by filing a motion to dismiss the Consolidated Complaint ("Motion to Dismiss");

WHEREAS, the parties, through their counsel, have agreed to a briefing and hearing schedule for Individual Defendants' Motion to Dismiss and believe that the current Case Management Conference scheduled for September 30, 2011 should be continued until after the hearing on the Motion to Dismiss;

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

1. Individual Defendants shall have until October 5, 2011 to file their response to the Consolidated Complaint which will be the Motion to Dismiss; Plaintiffs shall file their opposition brief by November 4, 2011; and Individual Defendants shall file their reply brief by November 18, 2011.

2. The Motion to Dismiss shall be scheduled for hearing on December 2 9, 2011, at 9:00 a.m. or at such other time as the Court shall order.

3. The Case Management Conference currently scheduled for September 30, 2011, at 2:30 p.m., shall be continued to December 2 9, 2011, immediately following the hearing on the Motion to Dismiss.

IT IS SO STIPULATED.

I, Sarah Good, am the ECF User whose ID and password are being used to file this Stipulation and [Proposed] Order Setting Briefing Schedule For Individual Defendants' Motion to Dismiss and Continuing Case Management Conference. In compliance with General Order 45, X.B., I hereby attest that Shawn Williams has concurred in this filing.

PURSUANT TO STIPULATION, IT IS SO ORDERED.