STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE INITIAL CASE MANAGEMENT CONFERENCE, RESET RELATED DEADLINES, AND EXTEND DEFENDANTS' TIME TO RESPOND TO THE COMPLAINT AS MODIFIED BY THE COURT

RICHARD SEEBORG, District Judge.

WHEREAS, on November 20, 2015, Plaintiff John Moran ("Plaintiff") filed a putative class action complaint ("Complaint") in the above-captioned action against defendants Clovis Oncology, Inc., Patrick J. Mahaffy, and Erle T. Mast (collectively, "Defendants") alleging violations of Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 ("Exchange Act"), 15 U.S.C. §§ 78j(b) and 78t(a), and Securities and Exchange Commission ("SEC") Rule 10b-5 promulgated thereunder, 17 C.F.R. § 240.10b-5.

WHEREAS, on December 4, 2015, Plaintiff sent service waivers to Defendants.

WHEREAS, this action is subject to the Private Securities Litigation Reform Act of 1995 ("PSLRA"). See 15 U.S.C. § 78u-4(a)(1). Under the PSLRA, the Court will appoint a lead plaintiff and lead counsel for the plaintiffs. 15 U.S.C. § 78u-4(a)(3)(B). After the lead plaintiff has been appointed, he or she will serve a consolidated amended complaint or designate a pending complaint as the operative complaint.

WHEREAS, the following related actions also arising under the Exchange Act and the PSLRA have been filed in the United States District Court for the District of Colorado alleging similar claims and facts against some or all of the same Defendants:

1. Medina v. Clovis Oncology, Inc., et al., Case No. 1:15-cv-2546 (D. Colo.; Filed November 19, 1015);

2. Kimbro v. Clovis Oncology, Inc., et al., Case No. 1:15-cv-2547 (D. Colo.; Filed November 19, 2015); and

3. Rocco v. Clovis Oncology, Inc., et al., Case No. 1:15-cv-2697 (D. Colo.; Filed December 14, 2015).

WHEREAS, the parties anticipate filing a motion or stipulation to consolidate this action and the three related actions referenced above, as well as any other subsequently-filed related action, into a single action either before this Court or the United States District Court for the District of Colorado.

WHEREAS, the parties agree that, in the interest of efficiency and the conservation of resources, Defendants' deadline to file a responsive pleading to the Complaint should be extended until after the appointment of a lead plaintiff and lead counsel.

WHEREAS, the parties believe that, in order to avoid the needless waste of the Court's and the parties' resources, it would be prudent to defer the initial case management conference and related deadlines (including ADR deadlines) until after the appointment of lead plaintiff and lead counsel.

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED as follows:

1. Defendants Clovis Oncology, Inc., Patrick J. Mahaffy, and Erle T. Mast accept service in this action.

2. Defendants' deadline to file a responsive pleading to the Complaint is vacated and further, that, within 10 days following appointment of a lead plaintiff and lead counsel, the parties will confer and submit a proposed scheduling order to the Court which includes deadlines for (1) lead plaintiff to serve a consolidated complaint, and (2) Defendants to file any responsive pleadings.

3. The case management conference presently scheduled for February 18, 2016, along with any associated deadlines under the Federal Rules of Civil Procedure and Local Rules (including ADR deadlines), is hereby continued to May 12, 2016 at 10:00 a.m.

4. This stipulation is entered into without prejudice to any party seeking any interim relief.

5. No party is waiving any rights, claims, or defenses of any kind except as expressly stated herein, and the parties reserve the right to seek further extensions of time as circumstances may warrant.

6. The parties have not sought any other extensions of time in this action.

7. The parties do not seek to reset these dates for the purpose of delay.

SIGNATURE ATTESTATION

I am the ECF User whose identification and password are being used to file the foregoing Stipulation and [Proposed] Order to Continue the Initial Case Management Conference, Reset Related Deadlines, and Extend Defendants' Time to Respond to the Complaint. In compliance with Civil Local Rule 5.1, I hereby attest that the other signatory has concurred in this filing.

[PROPOSED] ORDER

Pursuant to stipulation, IT IS SO ORDERED.