STIPULATION AND [PROPOSED] ORDER EXTENDING DEFENDANTS' RESPONSE DEADLINE AND VACATING INITIAL CASE MANAGEMENT CONFERENCE PENDING APPOINTMENT OF LEAD PLAINTIFF AND LEAD COUNSEL

[CIVIL L.R. 6-1, 6-2].

JON S. TIGAR, District Judge.

Pursuant to Civil Local Rules 6-1 and 6-2, all parties, through their undersigned counsel, hereby submit this Stipulation and [Proposed] Order deferring Defendants' deadlines to respond to the complaint in this action and vacating the Initial Case Management Conference and attendant deadlines.

RECITALS

A. On September 16, 2016, Plaintiff Doris Shenwick, as Trustee for the Doris Shenwick Trust, filed the above-captioned class action complaint in this Court. The complaint alleges violations of the federal securities laws by Twitter, Inc. and two of its current or former officers.

B. Upon commencement of the action, an Initial Case Management Conference was set for December 21, 2016, at 2:00 p.m.

C. Plaintiffs have not yet served any of the named defendants in this action.

D. This action is governed by the Private Securities Litigation Reform Act of 1995, 15 U.S.C. § 78u-4 et seq. (the "Reform Act"). Among other things, discovery is automatically stayed pending resolution of any motion to dismiss.

E. No meaningful litigation activity is expected until after the Court appoints lead plaintiff and lead counsel, at which point a consolidated complaint is likely to be filed by the Court-appointed lead plaintiff and lead counsel. After an operative complaint is filed, Defendants anticipate filing motions to dismiss that complaint.

F. Counsel for the undersigned parties agree that deferring the response deadlines for all defendants until after the Court appoints a lead plaintiff and lead counsel pursuant to the Reform Act is prudent and will conserve party and judicial resources. The parties further agree that the Initial Case Management Conference should be vacated and that attendant deadlines and related ADR procedures should be deferred until the Initial Case Management Conference is reset.

STIPULATION

NOW, THEREFORE, the undersigned hereby stipulate as follows:

1. The named defendants agree to accept service of the complaint in this action, through counsel.

2. The named defendants shall have no obligation to respond to the complaint in this action until after the Court appoints a lead plaintiff and lead counsel.

3. Counsel for Defendants will meet and confer with the Court-appointed lead counsel within fourteen days after the Court makes its appointment to discuss a schedule for the filing of any consolidated complaint and Defendants' responses thereto. The parties will thereafter submit a schedule to the Court for its consideration.

4. The Initial Case Management Conference that is presently scheduled for December 21, 2016 is hereby vacated and shall be reset in connection with the setting of the briefing schedule on Defendants' anticipated motions to dismiss. The related deadlines, including ADR requirements, shall be deferred until after an Initial Case Management Conference is reset.

[PROPOSED] ORDER

Pursuant to stipulation, it is SO ORDERED.