STIPULATED MOTION TO CONSOLIDATE RELATED ACTIONS AND APPOINT CO-LEAD COUNSEL AND LIAISON COUNSEL

RICARDO S. MARTINEZ, Chief District Judge.

WHEREAS, on September 8, 2017, David E. Mays ("Mays") filed a stockholder derivative complaint in this Court against defendants Hans E. Bishop, Richard D. Klausner, Robert T. Nelsen, Howard H. Pien, Hal V. Barron, Thomas O. Daniel, Anthony B. Evnin, Mary Agnes Wilderotter, Marc Tessier-Lavigne, and Steven D. Harr, styled Mays v. Bishop, et al., 2:17-cv-01356-RSM (the "Mays Action");

WHEREAS, on November 6, 2017, Paul Szollosi (together with Mays, "Plaintiffs") filed a stockholder derivative complaint in this Court against the defendants in the Mays Action, with the addition of Mark J. Gilbert (collectively, "Defendants"), styled Szollosi v. Bishop, et al., 2:17-cv-01665-RSL (the "Szollosi Action," and together with the Mays Action, the "Actions");

WHEREAS, on November 7, 2017, in the Mays Action the Court so-ordered a stipulation filed by the parties on November 2, 2017 setting Defendants' time to respond to the complaint, vacating discovery deadlines, and setting a briefing schedule for Defendants' motion to transfer;

WHEREAS, Defendants have waived service in the Mays Action and anticipate waiving service in the Szollosi Action;

WHEREAS, the Actions arise out of the same transactions and occurrences, involve the same or substantially similar issues of law and fact, and therefore, the Actions should be consolidated for all purposes into a single consolidated action ("the Consolidated Derivative Action");

WHEREAS, Plaintiffs and Defendants agree that consolidation is appropriate;

WHEREAS, Plaintiffs have met and conferred and have agreed that: (1) the law firms of Harwood Feffer LLP ("Harwood Feffer") and the Weiser Law Firm, P.C. ("Weiser Law Firm") should be appointed as Plaintiffs' Co-Lead Counsel in the Consolidated Derivative Action; and (3) the law firm of Zwerling, Schachter & Zwerling, LLP ("Zwerling Schachter") should be appointed as Liaison Counsel in the Consolidated Derivative Action;

WHEREAS, Defendants take no position as to the appointment of Plaintiffs' Co-Lead Counsel or Liaison Counsel in the Consolidated Derivative Action;

WHEREAS, the parties have met and conferred regarding Defendants' anticipated motion to transfer in the Mays Action, which is currently due on November 17, 2017 pursuant to the so-ordered stipulation signed by the Court on November 7, 2017 referenced above, and the fact that Defendants likewise intend to file a motion to transfer the Szollosi Action;

WHEREAS, the parties agree that it would be more efficient for the Court to hear a single motion to transfer in a consolidated action, if the Court approves this Stipulation, and that it therefore makes sense to postpone Defendants' motion to transfer until after the Court has ruled on this Stipulation;

NOW, THEREFORE, to conserve the resources of the Court and the litigants, the undersigned counsel for the parties hereby move the Court for an order as follows (with the proviso that Defendants take no position as to the appointment of Plaintiffs' Co-Lead Counsel or Liaison Counsel):

I. CONSOLIDATION

1. The Court finds that the Actions arise out of the same transactions and occurrences, involve the same or substantially similar issues of law and fact, and therefore, the Court has determined that the administration of justice would be served by consolidating the Actions.

2. The Actions are hereby consolidated for all purposes and are referred to herein as the Consolidated Derivative Action.

3. Every pleading filed in the Consolidated Derivative Action, or in any separate action included herein, must bear the following caption:

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON

4. The files of the Consolidated Derivative Action will be maintained in one file under Lead Case No. 2:17-cv-1356-RSM.

5. All documents previously served or filed in any of the Actions consolidated herein are deemed part of the record in the Consolidated Derivative Action.

6. The parties agree that when a case which properly belongs as part on in re Juno Therapeutics, Inc. Derivative Litigation, Lead Case No. 2:17-cv-1356-RSM, is hereafter filed in this Court or transferred here from another court, Co-Lead Counsel will call to the attention of the Clerk of the Court the filing or transfer of any case that might properly be consolidated as part of In re Juno Therapeutics, Inc. Derivative Litigation, Lead Case No. 2:17-cv-1356-RSM, and Co-Lead Counsel are to assist in assuring that counsel in subsequent actions receive notice of this Order.

7. This Order shall apply to each case arising out of the same or substantially the same transactions or events as the Consolidated Derivative Action that is subsequently filed in, removed to, or transferred to this Court.

II. BRIEFING SCHEDULE FOR MOTION TO TRANSFER

1. In order to avoid the necessity of filing duplicate motions in both the Mays Action and the Szollosi Action, the briefing schedule for Defendants' anticipated motion in the Mays Action is vacated.

2. Defendants shall file their motion to transfer no more than fourteen days after the Court rules on this stipulated motion, Plaintiffs shall file their opposition to the motion to transfer no more than 45 days later, and Defendants shall file their reply no more than 30 days after Plaintiffs file their opposition.

3. Defendants' deadline to file a motion to dismiss or other responsive pleading will be postponed until such time as the Court has ruled on the motion to transfer, and Defendants shall not be required to, and shall not waive any rights, arguments, or defenses by waiting to, answer, move, or otherwise respond to the Complaint.

4. After the Court rules on the motion to transfer, Plaintiffs and Defendants shall promptly meet and confer regarding a schedule for Defendants' anticipated motion(s) to dismiss the Complaint in either this Court or the transferee court in the District of Delaware.

III. APPOINTMENT OF CO-LEAD COUNSEL AND LIAISON COUNSEL

1. The law firms of Harwood Feffer and Weiser Law Firm are hereby appointed as Plaintiffs' Co-Lead Counsel in the Consolidated Derivative Action.

2. The law firm of Zwerling Schachter is hereby appointed as Liaison Counsel in the Consolidated Derivative Action.

3. Plaintiffs' Co-Lead Counsel are authorized to speak for Plaintiffs in matters regarding pre-trial procedure, trial and settlement negotiations and shall make all work assignments in such manner as to facilitate the orderly and efficient prosecution of this litigation and to avoid duplicative or unproductive effort.

4. Plaintiffs' Co-Lead Counsel will be responsible for coordinating all activities and appearances on behalf of Plaintiffs and for the dissemination of notices and orders of this Court. No motion, request for discovery, or other pre-trial or trial proceedings will be initiated or filed by any Plaintiffs except through Plaintiffs' Co-Lead Counsel.

5. Defendants' counsel may rely upon all agreements made with Plaintiffs' Co-Lead Counsel, or any other duly authorized representative of Plaintiffs' Co-Lead Counsel, and such agreements will be binding on Plaintiffs.

IT IS SO ORDERED.