CLASS ACTION

STIPULATION AND ORDER RE AMENDMENT TO THE NOTICE OF PENDENCY OF CLASS ACTION

RICARDO S. MARTINEZ, District Judge.

Plaintiffs Gilbert Hoang Nguyen and Susan Tan ("Plaintiffs") and Defendants Juno Therapeutics, Inc., Hans E. Bishop, Steven D. Harr, and Mark J. Gilbert (collectively, "Defendants") having met and conferred, submit the following Stipulation Regarding Amendment to the Notice of Pendency of Class Action, and ask the Court to enter an Order consistent with this Stipulation.

WHEREAS, on December 21, 2017, Plaintiffs filed an unopposed motion for an Order establishing a program and schedule for notice to the class of pending class action (Dkt. No. 109);

WHEREAS, the Notice of Pendency of Class Action required any class member seeking exclusion to timely mail a request for exclusion no later than March 19, 2018 (Dkt. No. 109-1);

WHEREAS, on December 22, 2017, the Court entered an Order granting Plaintiffs' unopposed motion for an Order establishing a program and schedule for notice to the class of pending class action, and approved the Notice of Pendency of Class Action and the Summary Notice (Dkt. No. 110);

WHEREAS, the parties have been working with the claims administrator to identify a complete list of shareholders identified on the books and records of the Company;

WHEREAS, the average time required to allow a shareholder to request exclusion is typically between 45 and 60 days from the date the notice is mailed;

WHEREAS, some shareholders may not have sufficient time to request exclusion from the deadline given that the current deadline is on March 19, 2018;

NOW, THEREFORE, the parties stipulate and agree as follows:

IT IS SO STIPULATED.

ORDER

IT IS SO ORDERED.