STIPULATION AND [PROPOSED] ORDER ON CASE MANAGEMENT CONFERENCE STATEMENT

EDWARD M. CHEN, District Judge.

WHEREAS, on May 19, 2011, plaintiffs Curtis and Charlotte Westley filed a Class Action Complaint for Violation of the Federal Securities Laws ("Complaint") (Dkt. No. 1) against defendants Oclaro, Inc., Alain Couder, Jerry Turin, and James Haynes in the above-entitled matter;

WHEREAS, on October 27, 2011, Lead Plaintiff Connecticut Laborers' Pension Fund ("Lead Plaintiff") filed an Amended Complaint for Violation of the Federal Securities Laws ("Amended Complaint") (Dkt. No. 39) against Defendants Oclaro, Inc., Alain Couder, and Jerry Turin (collectively, "Defendants");

WHEREAS, on December 12, 2011, Defendants filed a motion to dismiss the Amended Complaint (Dkt. No. 44);

WHEREAS, on March 27, 2012, the Court issued an Order granting Defendants' motion to dismiss the Amended Complaint and Lead Plaintiff leave to amend (Dkt. No. 58);

WHEREAS, on April 26, 2012, Lead Plaintiff filed a Second Amended Complaint for Violation of the Federal Securities Laws ("Second Amended Complaint") (Dkt. No. 62);

WHEREAS, on May 25, 2012, Defendants filed a motion to dismiss the Second Amended Complaint (Dkt. No. 63);

WHEREAS, on September 21, 2012, the Court issued an Order granting Defendants' motion to dismiss the Second Amended Complaint and Lead Plaintiff leave to amend ("September 21 Order") (Dkt. No. 79);

WHEREAS, on October 4, 2012, Lead Plaintiff filed a Motion for Leave to File Motion for Reconsideration of the September 21 Order ("Motion for Leave") (Dkt. No. 82);

WHEREAS, on October 29, 2012, the Court issued notice rescheduling the Case Management Conference for December 11, 2012 and the filing of the parties' Joint Case Management Statement for December 4, 2012 (Dkt. No. 90);

WHEREAS, on October 30, 2012, Defendants filed an Opposition to Lead Plaintiff's Motion for Leave (Dkt. No. 91);

WHEREAS, on November 17, 2012, Lead Plaintiff filed a Reply in Support of the Motion for Leave (Dkt. No. 93);

WHEREAS, on December 11, 2012, the Court will hold a hearing on Lead Plaintiff's Motion for Leave;

WHEREAS, pursuant to the Private Securities Litigation Reform Act of 1995, 15 U.S.C. § 78u-4(b)(3)(B), discovery is currently stayed during the pendency of Defendants' motion to dismiss;

WHEREAS, based on the discovery stay and in order to avoid the unnecessary expenditure of the Court's resources or effort by the parties to this action, the parties have agreed, subject to the Court's approval, that there is no need at this time for the parties to file the Joint Case Management Conference Statement; and

WHEREAS, this Stipulation and Order is without prejudice to, or waiver of, any rights, arguments, or defenses otherwise available to the parties to this action.

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

SIGNATURE ATTESTATION

I am the ECF User whose identification and password are being used to file the foregoing Stipulation and [Proposed] Order on Case Management Conference Statement. Pursuant to General Order No. 45, Section X (B) regarding signatures, I, Gidon M. Caine, attest that concurrence in the filing of this document has been obtained.