STIPULATION, DECLARATION, AND ORDER TO CONTINUE ORAL ARGUMENT AND CASE MANAGEMENT CONFERENCE

SAUNDRA BROWN ARMSTRONG, District Judge.

WHEREAS, pursuant to stipulation of the parties and the Court's Order on December 24, 2013 (ECF No. 46), the initial case management conference was continued to July 24, 2014 at 3:00 pm;

WHEREAS, on February 3, 2014, Lead Plaintiffs filed a Consolidated Amended Complaint (ECF No. 48);

WHEREAS, Defendants Credit Suisse International and Credit Suisse Securities (USA) LLC ("Defendants") filed a Motion to Dismiss the Consolidated Amended Complaint ("Motion to Dismiss") on April 4, 2014 (ECF No. 53), and the hearing for the Motion to Dismiss is set for September 9, 2014 (ECF No. 62);

WHEREAS, as detailed in the accompanying Declaration of Thomas Laughlin, counsel for Lead Plaintiffs, a conflict has arisen with respect to the September 9, 2014 hearing date for the Motion to Dismiss in that the Ninth Circuit has scheduled oral argument in another case for that date; and

WHEREAS, the parties agree that the interests of judicial economy and efficiency would best be served by postponing the case management conference until after the hearing on the Motion to Dismiss;

THEREFORE, IT IS HEREBY STIPULATED AND AGREED by all parties through their respective counsel of record, that:

IT IS SO STIPULATED.

Pursuant to Local Rule 6-2, this Stipulation is supported by the following Declaration of Thomas Laughlin.

DECLARATION OF THOMAS LAUGHLIN

I, Thomas Laughlin, declare:

1. I am an attorney at Scott+Scott, Attorneys at Law, LLP, counsel for Plaintiffs in this action. I have the principal responsibility for arguing on behalf of Lead Plaintiffs at oral argument regarding Defendants' Motion to Dismiss. I make this Declaration in support of the parties' stipulation to continue the oral argument and case management conference scheduled in this action.

2. The parties have stipulated to these continuances at my request.

3. Oral argument in this matter is presently scheduled for September 9, 2014.

4. On July 3, 2014, the United States Court of Appeals for the Ninth Circuit scheduled oral argument on September 9, 2014 in Saginaw Police & Fire Pension v. Andreessen, No. 12-16473. I am the attorney arguing that appeal. I cannot ask the Ninth Circuit to reschedule that hearing date as I have already done so once, when the oral argument was initially scheduled during a trial pending in the United States District Court for the District of Maine, in Bankers' Bank Northeast v. Berry Dunn McNeil & Parker, No. 12-cv-127.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on July 9, 2014 at New York, New York.

PURSUANT TO THIS STIPULATION IT IS SO ORDERED.