STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT AND POSTPONE CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES

RICHARD SEEBORG, District Judge.

WHEREAS, on February 13, 2018, Plaintiff Steven Lazan, individually and on behalf of all others similarly situated, filed a Class Action Complaint for Violations of the Federal Securities Laws ("Complaint") against Quantum Corporation ("Quantum") and certain of its current and former officers and directors, Jon Gacek, Fuad Ahmad, and Adalio T. Sanchez (collectively, "Defendants");

WHEREAS, Defendants waived service of the Complaint, and their responses to the Complaint are currently due June 11, 2018;

WHEREAS, on February 13, 2018, the Court entered an Order Setting Initial Case Management Conference and ADR Deadlines (ECF No. 3) ("CMC Order") which, among other things, set an Initial Case Management Conference ("Initial CMC") for May 17, 2018;

WHEREAS, the CMC Order further set May 10, 2018 as the last day for the parties to file a Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report, and file a Case Management Statement per Standing Order re Contents of Joint Case Management Statement, and set April 26, 2018 as the last day for the parties to meet and confer regarding initial disclosures, early settlement, Alternative Dispute Resolution ("ADR") process selection, and a discovery plan, and file an ADR Certification with either a Stipulation to ADR Process or a Notice of Need for ADR Phone Conference;

WHEREAS, this action is governed by the provisions of the Private Securities Litigation Reform Act of 1995 ("PSLRA"), 15 U.S.C. § 78u-4 et seq., and the parties anticipate that the Court will appoint a lead plaintiff and that the court-appointed lead plaintiff will file a consolidated complaint superseding previously filed complaints, including the Complaint; and

WHEREAS, the parties agree that efficiency for the Court and the parties in proceeding under the PSLRA dictates that responding to the current Complaint should be deferred.

THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among the respective parties hereto, that:

1. After the appointment of a lead plaintiff pursuant to 15 U.S.C. § 78u-4(a)(3)(B), lead plaintiff and Defendants shall promptly meet and confer regarding a schedule for the filing of a consolidated complaint or designation of an operative complaint, and a briefing schedule for Defendants' anticipated motion(s) to dismiss. The parties shall submit a joint stipulation with a proposed schedule no later than ten (10) business days following the appointment of lead plaintiff.

2. Defendants shall not be required to move to dismiss, or otherwise respond to, the Complaint in this action, and shall not be deemed to have waived any rights, arguments, or defenses by waiting to respond, until such time as Defendants are required to respond pursuant to the Court-approved schedule.

3. The parties request that the Court vacate the Initial CMC currently scheduled for May 17, 2018, to be rescheduled to a later date at the Court's convenience, which will accordingly continue all related deadlines set forth in the CMC Order.

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

5. Nothing in this Stipulation shall be construed as a waiver of any of Defendants' rights or positions in law or in equity, or as a waiver of any defenses that Defendants would otherwise have, including, without limitation, jurisdictional defenses.

IT IS SO STIPULATED.

[PROPOSED] ORDER

GOOD CAUSE HAVING BEEN SHOWN, it is hereby ordered that:

1. After the appointment of a lead plaintiff pursuant to 15 U.S.C. § 78u-4(a)(3)(B), lead plaintiff and Defendants shall promptly meet and confer regarding a schedule for the filing of a consolidated complaint or designation of an operative complaint, and a briefing schedule for Defendants' anticipated motion(s) to dismiss. The parties shall submit a joint stipulation with a proposed schedule no later than ten (10) business days following the appointment of lead plaintiff.

2. Defendants shall not be required to move to dismiss, or otherwise respond to, the Complaint in this action, and shall not be deemed to have waived any rights, arguments, or defenses by waiting to respond, until such time as Defendants are required to respond pursuant to the Court-approved schedule.

3. The Initial CMC currently set in this matter for May 17, 2018 is hereby vacated and will be rescheduled at a later date consistent with the foregoing stipulation. All related deadlines set forth in this Court's Order Setting Initial Case Management Conference and ADR Deadlines (ECF No. 3) will be continued accordingly.

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

5. Nothing in this Stipulation shall be construed as a waiver of any of Defendants' rights or positions in law or in equity, or as a waiver of any defenses that Defendants would otherwise have, including, without limitation, jurisdictional defenses.

IT IS SO ORDERED.