STIPULATION AND [PROPOSED] ORDER REGARDING CONTINUANCE OF CASE MANAGEMENT CONFERENCES AND EXTENDING DEFENDANTS' TIME TO RESPOND TO COMPLAINTS

(Civ. L.R. 3-12)

RICHARD SEEBORG, District Judge.

WHEREAS, the complaints in the above-captioned related shareholder class actions set forth claims under the federal securities laws that are subject to the requirements of the Private Securities Litigation Reform Act of 1995 ("PSLRA"), including those set forth in 15 U.S.C. § 78u-4;

WHEREAS, the PSLRA requires that, after filing a securities class action, the plaintiff must give notice of the action to allow other interested shareholders the opportunity to file motions for appointment as lead plaintiff (see 15 U.S.C. § 78u-4(a)(3)) and, thereafter, that the Court appoint a lead plaintiff;

WHEREAS, on October 17, 2016, multiple movants filed competing motions seeking to be appointed lead plaintiff and to consolidate the Bristow and Patel actions (Dkt. Nos. 13, 17, 18, 22, 26);

WHEREAS, the hearing regarding the lead plaintiff motions is scheduled for December 8, 2016;

WHEREAS, pursuant to the August 18, 2016 Order Setting Initial Case Management Conference in the Bristow action, a Case Management Conference was scheduled for November 17, 2016 and subsequently continued to November 18, 2016 pursuant to the Clerk's Notice issued November 1, 2016;

WHEREAS, prior to reassignment to this Court, a Case Management Conference in the Patel action was set for November 29, 2016;

WHEREAS, to avoid unnecessary expenditure of judicial resources or effort by the parties and the Court, counsel for plaintiffs in the Bristow and Patel actions and defendants have agreed (1) that defendants need not respond to the Bristow and Patel complaints or the complaint in any action consolidated into this action, other than an amended or consolidated complaint or a complaint designated as the operative complaint after the appointment of lead plaintiff; and (2) to continue the Initial Case Management Conferences in the Bristow and Patel actions and associated deadlines until after a lead plaintiff has been appointed to represent the alleged class.

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among counsel for the undersigned parties, subject to approval of the Court, as follows:

1. Defendants are not required to respond to the Bristow and Patel complaints or the complaint in any action consolidated into this action, other than an amended or consolidated complaint or a complaint designated as the operative complaint after the appointment of lead plaintiff.

2. The Initial Case Management Conferences ("CMC") in the Bristow and Patel actions, currently scheduled for November 18, 2016, and November 29, 2016, respectively, and the associated CMC and ADR deadlines in the Bristow and Patel actions, shall be vacated and are hereby adjourned to such other date and time as this Court shall order.

PURSUANT TO STIPULATION, IT IS SO ORDERED.