STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND TO SUMMONS AND COMPLAINT

JOHN S. BRYANT, Magistrate Judge.

Whereas, Plaintiff North Port Firefighters' Pension — Local Option Plan ("Plaintiff") filed the above-captioned putative shareholder class action on June 20, 2011;

Whereas, on May 6, 2011, pursuant to the Private Securities Litigation Reform Act (the "PSLRA") (15 U.S.C. § 78u-4(a)(3)(A)(i)), in a related action filed in the United States District Court for the Southern District of New York, a notice was issued that, among other things, notified proposed class members that a class action suit was filed against Fushi Copperweld, Inc. ("Fushi Copperweld" or the "Company") for violations of the Securities Exchange Act of 1934 on behalf of purchasers of the Company's common stock during the period August 14, 2007 through March 29, 2011, inclusive, and that members of the proposed class may move the Court to serve as a lead plaintiff for the proposed Class no later than sixty days from the date of the notice, or by July 5, 2011;

Whereas, on June 20, 2011, following the filing of the above-captioned action, a notice was issued that, among other things, notified proposed class members that a class action suit was filed against Fushi Copperweld for violations of the Securities Exchange Act of 1934 in the United States District Court for the Middle District of Tennessee on behalf of purchasers of the Company's common stock during the period August 14, 2007 through May 4, 2011, inclusive, and that members of the proposed class may move the Court to serve as a lead plaintiff for the proposed Class no later than sixty days from May 6, 2011.

Whereas, pursuant to the PSLRA, motions for the appointment as lead plaintiff were filed on July 5, 2011;

Whereas, pursuant to 15 U.S.C. § 78u-4(a)(3)(B)(i)-(ii), the Court shall consider any motions to consolidate any related cases and any motions for appointment of lead plaintiff, and shall appoint as lead plaintiff the member or members of the proposed class that the Court determines to be most capable of adequately representing the interests of the proposed class;

Whereas, after the Court appoints a lead plaintiff and lead counsel, the parties shall confer concerning a schedule for the filing of a consolidated complaint and any motions to dismiss the complaint and related briefing;

Whereas, counsel for Plaintiff and counsel for Defendants Fushi Copperweld, Inc. ("Fushi Copperweld"), Joseph J. Longever ("Longever"), and Craig H. Studwell ("Studwell") have conferred for the purpose of ensuring that the action proceed in an efficient and orderly manner;

Whereas, Fushi Copperweld currently must move, answer, or otherwise respond to the Summons and Complaint by July 14, 2011, and Longever and Studwell must move, answer, or otherwise respond to the Summons and Complaint by July 13 and July 15, 2011, respectively;

Whereas, Fushi Copperweld, Longever, and Studwell have not previously requested an extension of time to respond to the Summons and Complaint; and

Whereas, by entering into this Stipulation, the parties reserve all rights, including without limitation, that Fushi Copperweld, Longever, and Studwell do not expressly or implicitly waive, and hereby expressly reserve, any and all of their rights, claims, and defenses to any claims that Plaintiff has asserted or may assert in the future, including defenses based upon ineffective service of process and lack of personal jurisdiction.

IT IS THEREFORE STIPULATED AND AGREED, by and between Plaintiff and Defendants Fushi Copperweld, Longever, and Studwell, by and through their undersigned counsel and subject to the approval of this Court, that:

Within sixty days after the Court's appointment of a lead plaintiff and lead counsel, lead plaintiff shall file a consolidated complaint. The time for Defendants Fushi Copperweld, Longever, and Studwell to move, answer, or otherwise respond to the Summons and Complaint in this action shall be extended up to and including a date sixty (60) days after lead plaintiff's filing and service of a consolidated complaint.

IT IS SO ORDERED.