STIPULATION AND ORDER REGARDING FILING OF AMENDED COMPLAINT AND BRIEFING SCHEDULE FOR MOTION(S) TO DISMISS

HAYWOOD S. GILLIAM, Jr., District Judge.

WHEREAS, this action for violations of the federal securities laws was filed against defendants Solazyme, Inc. (now called TerraVia, Inc.), Jonathan S. Wolfson, Tyler W. Painter, David C. Cole, Jerry Fiddler, Michael V. Arbige, Ian T. Clark, Peter Kovacs, James R. Craigie, ("Solazyme Defendants") Goldman, Sachs & Co., and Morgan Stanley & Co. LLC ("Underwriter Defendants"), (collectively "Defendants");

WHEREAS, on October 8, 2015, the Court entered an order appointing plaintiffs John Medlin, John Hussain, Norfolk County Retirement System, Nancy Ackels, and Leonardo Fernandez as lead plaintiffs ("Lead Plaintiffs");

WHEREAS, Lead Plaintiffs filed a Consolidated Class Action Complaint and Defendants filed motions to dismiss the complaint;

WHEREAS, on December 29, 2016, the Court issued an Order granting Defendants' motions to dismiss with leave to amend, and set January 26, 2017 as the deadline to file an amended complaint;

WHEREAS, Plaintiffs have requested additional time to file their First Amended Complaint;

WHEREAS, counsel for the parties have conferred regarding a mutually-agreeable schedule for the filing of the amended complaint and for briefing of Defendants' anticipated motion(s) to dismiss;

NOW THEREFORE, subject to the approval of the Court, the parties hereby agree and stipulate to the following:

1. Lead Plaintiffs shall file an amended complaint on or before February 15, 2017;

2. Any motion(s) to dismiss the amended complaint shall be filed on or before March 17, 2017;

3. Lead Plaintiffs' opposition to Defendants' motion(s) to dismiss shall be filed on or before April 17, 2017;

4. Defendants' reply in support of any motion(s) to dismiss shall be filed on or before May 17, 2017; and

5. The hearing on Defendants' motion(s) to dismiss will be held on June 1, 2017, at 2:00 p.m., or on such other day and time as set by the Court.

ATTESTATION

I, Ex Kano S. Sams II, am the ECF User whose identification and password are being used to file this STIPULATION AND [PROPOSED] ORDER REGARDING FILING OF AMENDED COMPLAINT AND BRIEFING SCHEDULE FOR MOTION(S) TO DISMISS. In compliance with Civil L.R. 5-1, I hereby attest that Mark R.S. Foster and Simona G. Strauss have concurred in this filing.

ORDER

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.