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In re Schwab Corp. Securities Litigation

May 14, 2009

IN RE SCHWAB CORP. SECURITIES LITIGATION


The opinion of the court was delivered by: The Honorable William Alsup United States District Judge

THIS DOCUMENT RELATES TO: All Actions

STIPULATION AND [PROPOSED] ORDER RE: REMOVAL OF PLAINTIFFS GRETCHEN MIKELONIS AND KARL KYZER

Date Action Filed: March 18, 2008

WHEREAS, on July 3, 2008, the Court appointed seven lead plaintiffs, including Gretchen Mikelonis and her husband David Mikelonis (Docket No. 73); complaint filed on October 2, 2008 (Docket No. 104 ¶ 21) and the proposed second consolidated amended complaint filed on February 26, 2009 (Docket No. 170-2 ¶ 21);

WHEREAS, Karl Kyzer was named as a plaintiff in the first consolidated amended complaint filed on October 2, 2008 (Docket No. 104 ¶ 23) and the proposed second consolidated amended complaint filed on February 26, 2009 (Docket No. 170-2 ¶ 21); take place on May 14, 2009 and May 15, 2009, respectively;

WHEREAS, Gretchen Mikelonis was named as a plaintiff in the first consolidated amended

WHEREAS, defendants noticed the depositions of Gretchen Mikelonis and Karl Kyzer to

WHEREAS, plaintiffs filed their motion for class certification and did not name Gretchen Mikelonis or Karl Kyzer as proposed class representatives; named plaintiff and both Gretchen Mikelonis and Karl Kyzer as named plaintiffs;

WHEREAS, the plaintiffs now wish to withdraw Gretchen Mikelonis as a lead plaintiff and

IT IS HEREBY STIPULATED AND AGREED among the undersigned parties, subject to Court approval, as follows:

amended complaint and the proposed second consolidated amended complaint;

Gretchen Mikelonis is withdrawn as a lead plaintiff in the above-captioned action;

Gretchen Mikelonis and Karl Kyzer are stricken as plaintiffs from the ...


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