JON S. TIGAR, District Judge.
Lead Plaintiff Union Asset Management Holding AG ("Union") respectfully submits this stipulation and proposed order with regard to the appointment of Lead Counsel in the above-captioned matter.
1. WHEREAS, the Private Securities Litigation Reform Act ("PSLRA") requires the Lead Plaintiff to select and retain counsel to represent the class, subject to Court approval (see 15 U.S.C. § 78u-4(a)(3)(B)(v));
2. WHEREAS, on January 5, 2017, the Court appointed Union to serve as Lead Plaintiff in this action and approved Union's selection of Motley Rice LLC ("Motley Rice") as Lead Counsel;
3. WHEREAS, Union has conducted an internal review of its active litigation, including its selection of Lead Counsel in this action;
4. WHEREAS, as part of that review, Union retained Bernstein Litowitz Berger & Grossmann LLP ("Bernstein Litowitz") to represent it and the proposed class in this action, subject to the approval of the Court, and terminated its relationship with Motley Rice in this case;
5. WHEREAS, Motley Rice has agreed to withdraw as Lead Counsel, and Union seeks to substitute Bernstein Litowitz as Lead Counsel in this case;
6. WHEREAS, Motley Rice does not oppose the substitution of Bernstein Litowitz as Lead Counsel in this action;
7. WHEREAS, Bernstein Litowitz has significant experience serving as Lead Counsel in securities class actions and has a proven history of handling this type of complex litigation in this District and in courts throughout the Country (see Bernstein Litowitz's Firm Résumé, submitted herewith as Exhibit A to the accompanying Declaration of Blair A. Nicholas);
8. WHEREAS, counsel for Union—Bernstein Litowitz—informs all of the undersigned that on May 12, 2017, it contacted counsel for Defendants regarding substitution of counsel, and Defendants have no objection to the relief sought herein;
1. Union's selection of Bernstein Litowitz to serve as Lead Counsel in the above-captioned action is approved.
2. Motley Rice is withdrawn as Lead Counsel in the above-captioned matter.
I, Shawn A. Williams, in compliance with Civil Local Rule 5.1(i), hereby attest that I obtained the concurrence of all of the above-listed counsel in filing this document.