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In re PMI Group

June 13, 2008

IN RE THE PMI GROUP, INC. SECURITIES LITIGATION


The opinion of the court was delivered by: The Honorable Susan Illston United States District Judge

STIPULATION AND [PROPOSED] ORDER VACATING DATE FOR INITIAL THIS DOCUMENT RELATES TO: CASE MANAGEMENT CONFERENCE ALL ACTIONS AND REMOVING CASE FROM AUTOMATIC REFERRAL TO THE ADR MULTI-OPTION PROGRAM PURSUANT TO ADR LOCAL RULE 3-3(c)

Management Conference for June 20, 2008; related and consolidated action, Holt v. The PMI Group, Inc. et al., Case No. C-08-1806 SI; parties to comply with various procedures, including initial disclosures, and the filing of a Rule Conference;

Reform Act of 1995 (the "PSLRA") which requires the appointment of a lead plaintiff and lead counsel to represent plaintiff, provides for the filing of a consolidated amended complaint by the lead plaintiff and counsel for the lead plaintiff, and imposes a discovery stay pending resolution of a motion to dismiss the consolidated amended complaint; action, and no consolidated amended complaint has been filed and discovery remains stayed; Initial Case Management Conference are incompatible with the requirements of the PSLRA, and that the scheduling of an Initial Case Management Conference in this action is premature;

Multi-Option program pursuant to ADR L.R. 3-3(c) because the undersigned parties do not believe, at this time, that the Multi-Option program will facilitate resolution of the matter; the course of this litigation, and in the event that the parties elect to pursue ADR options, will contact the Court to provide updates and/or seek guidance as such efforts proceed; request that the Court enter an order, as follows:

STIPULATION

WHEREAS, the initial complaint in this action was filed on March 12, 2008;

WHEREAS, the Order assigning the action to Judge Illston set an Initial Case

WHEREAS, an Initial Case Management Conference was set for July 18, 2008, in the

WHEREAS, the Order setting the Initial Case Management Conference requires the 26(f) Report and Joint Case Management Conference Statement, in connection with the

WHEREAS, this action is subject to the provisions of the Private Securities Litigation

WHEREAS, there has been no appointment of a lead plaintiff or lead counsel in this

WHEREAS, the parties believe that the procedures to be completed in connection with the

WHEREAS, the undersigned parties agree that the case should be removed from the ADR

WHEREAS, the parties will discuss ADR options as appropriate on an ...


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