STIPULATION AND [PROPOSED] ORDER TO FILE BRIEFS RE MOTION TO DISMISS IN EXCESS OF 15 PAGES

JEFFREY S. WHITE, District Judge.

WHEREAS, on April 3, 2013, Lead Plaintiff David Fee and Named Plaintiff Joy Arjoon-Singh ("Plaintiffs") filed the Consolidated Complaint ("Complaint") in the above-entitled matter;

WHEREAS, Defendants Zynga Inc., Mark Pincus, David M. Wehner, John Schappert, Mark Vranesh, William Gordon, Reid Hoffman, Jeffrey Katzenberg, Stanley J. Meresman, Sunil Paul, and Owen Van Natta (collectively, the "Zynga Defendants"), and Morgan Stanley & Co. LLC, Goldman, Sachs & Co., J.P. Morgan Securities LLC, Merrill Lynch, Pierce, Fenner & Smith Incorporated, Barclays Capital Inc., and Allen & Company LLC (collectively, "the Underwriter Defendants," and together with the Zynga Defendants, "Defendants") are scheduled to file their motions to dismiss on May 31, 2013; Plaintiffs' oppositions to the motions to dismiss are due on July 12, 2013; and Defendants' replies in support of their motions to dismiss are due on August 9, 2013;

WHEREAS, all of the Defendants intend on filing motions to dismiss, with the Zynga Defendants making their arguments together in a single motion, and the Underwriter Defendants making their arguments together in a single motion;

WHEREAS, although Civil Local Rules 7-2 and 7-3 allow for the filing of briefs up to 25 pages in length, this Court's Standing Order limits briefs on motions to dismiss to 15 pages;

WHEREAS, the Complaint includes 386 numbered paragraphs over 110 pages and asserts six causes of action—three under the Securities Act of 1933 (for violations of Sections 11, 12(a)(2), and 15) and three under the Securities Exchange Act of 1934 (for violations of Sections 10(b), 20(a), and 20A)—against 17 Defendants;

WHEREAS, the parties have conferred, and believe that in light of the number and complexity of issues presented by the Zynga Defendants' anticipated motion to dismiss, including the fact that the motion to dismiss will be filed on behalf of multiple defendants, it will be helpful to the parties and to the Court, to permit the Zynga Defendants to file their opening brief on their motion to dismiss not to exceed 30 pages, for Plaintiffs to file a brief opposing the Zynga Defendants' motion not to exceed 30 pages, and for the Zynga Defendants to file a reply brief not to exceed 15 pages, exclusive of title pages, indices of cases tables of contents, exhibits, and summaries of argument.

THEREFORE, IT IS HEREBY STIPULATED AND AGREED among the undersigned parties that, subject to Court approval, the Zynga Defendants may file their opening brief on their motion to dismiss not to exceed 25 pages, Plaintiffs may file a brief opposing the Zynga Defendants' motion not to exceed 25 pages, and the Zynga Defendants may file a reply brief not to exceed 15 pages, exclusive of title pages, indices of cases, tables of contents, exhibits, and summaries of arguments.