STIPULATION AND ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES

WILLIAM H. ORRICK, District Judge.

WHEREAS, on August 22, 2013, plaintiff Anika R. Rieckborn ("Plaintiff") filed a "Class Action Complaint for Violations of the Federal Securities Laws," and the above-captioned Rieckborn Action was assigned to this Court;

WHEREAS, on August 26, 2013, plaintiff Chris Vafinis filed a "Class Action Complaint for Violations of the Federal Securities Laws," and the above-captioned Vafinis Action was assigned to Judge Yvonne Gonzalez Rogers;

WHEREAS, on September 6, 2013, plaintiff Han Lee filed a "Class Action Complaint for Violations of the Federal Securities Laws," and the above-captioned Lee Action was assigned to Judge Susan Illston;

WHEREAS, on October 4, 2013, plaintiff Raymund Manabat filed a "Class Action Complaint for Violations of the Federal Securities Laws," and the above-captioned Manabat Action was assigned to Magistrate Judge Jacqueline Scott Corley;

WHEREAS, on October 21, 2013, various movants filed motions to consolidate the above-captioned Rieckborn, Vafinis, Lee, and Manabat Actions, to appoint a Lead Plaintiff pursuant to the requirements of the Private Securities Litigation Reform Act of 1995 (the "Reform Act"), and to approve the selection of Lead Counsel (the "Consolidation Motions");

WHEREAS, a hearing on the Consolidation Motions is scheduled before the Court on November 27, 2013;

WHEREAS, an Initial Case Management Conference in the above-captioned Rieckborn Action is scheduled for November 26, 2013 at 2:00 p.m., and a Joint Case Management Statement is due to be filed by November 19, 2013;

WHEREAS, in light of the pending Consolidation Motions and the requirements of the Reform Act, and to avoid unnecessary expenditure of judicial resources or effort by the parties and the Court, counsel for Plaintiff and Defendant Velti have agreed, subject to approval of the Court, that: (1) the November 26, 2013 Initial Case Management Conference ("CMC") and related CMC and ADR deadlines in the Rieckborn Action shall be adjourned pending a determination on consolidation and the appointment of a Lead Plaintiff; and (2) Defendant need not respond to the individual complaint in the Rieckborn Action, other than a consolidated complaint or a complaint designated as the operative complaint after the appointment of a Lead Plaintiff; and

WHEREAS, the requested continuances are not for the purpose of delay and will not prejudice any party.

THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned, subject to approval of the Court:

1. The November 26, 2013 Initial Case Management Conference and related CMC and ADR deadlines in the Rieckborn Action are hereby adjourned, pending a determination on consolidation and the appointment of a Lead Plaintiff, to such other date and time as this Court shall order.

2. Defendant is not required to respond to the individual complaint in the Rieckborn Action, other than a consolidated complaint or a complaint designated as the operative complaint after the appointment of a Lead Plaintiff.

ORDER

Upon stipulation of the parties, and good cause appearing:

IT IS SO ORDERED. The new setting for the Case Management Conference shall be January 7, 2014 at 2:00 p.m.