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Port Authority of Allegheny County Retirement and Disability Allowance Plan for Employees represented by Local 85 of the Amalgamated Transit Union v. Smith

December 14, 2009

THE PORT AUTHORITY OF ALLEGHENY COUNTY RETIREMENT AND DISABILITY ALLOWANCE PLAN FOR EMPLOYEES REPRESENTED BY LOCAL 85 OF THE AMALGAMATED TRANSIT UNION PLAINTIFF,
v.
L. STEPHEN SMITH, W. ROGER HAUGHTON, DAVID H. KATKOV, DONALD P LOFE, JR., MARIANN BYERWALTER, DR. JAMES C. CASTLE, CARMINE GUERRO, WAYNE E. HEDIEN, LOUIS G. LOWER, II, RAYMOND L. OCAMPO JR., JOHN D. ROACH, DR. KENNETH T. ROSEN, STEVEN L. SCHEID, JOSE H. VILLARREAL, MARY LEE WIDENER, AND RONALD H. ZECH DEFENDANTS, AND PMI GROUP, INC., NOMINAL DEFENDANT.



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

STIPULATION AND [PROPOSED] ORDER

Plaintiff, the Port Authority of Allegheny County Retirement and Disability Allowance Plan for Employees Represented by Local 85 of the Amalgamated Transit Union ("Plaintiff" or "ATU 85"), defendants L. Stephen Smith, W. Roger Haughton, David H. Katkov, Donald P. Lofe, Jr., Mariann Byerwalter, Dr. James C. Castle, Carmine Guerro, Wayne E. Hedien, Louis G. Lower, II, Raymond L. Ocampo Jr., John D. Roach, Dr. Kenneth T. Rosen, Steven L. Scheid, Jose H. Villarreal, Mary Lee Widener, and Ronald H. Zech (collectively, the "Individual Defendants"), and nominal defendant, The PMI Group, Inc., ("PMI" or the "Company") hereby submit the following Stipulation and [Proposed] Order ("Order"):

WHEREAS, on June 26, 2008, this Court entered a Stipulated Case Management Order;

WHEREAS, pursuant to the Case Management Order, the above-captioned action was stayed pending resolution of a motion to dismiss the related shareholder class action captioned In re The PMI Group, Inc. Securities Litigation, Master File No. 3:08-cv-01405-SI (the "Securities Class Action");

WHEREAS, on November 2, 2009, the Court entered an Order Denying Defendants' Motion to Dismiss First Amended Complaint in the Securities Class Action;

WHEREAS, pursuant to the Case Management Order, Plaintiff is currently required to file an amended complaint 45 days after the lifting of the stay of discovery in the Securities Class Action; and

WHEREAS, the parties have met and conferred and agree that, in order to address scheduling conflicts of counsel for both parties and issues related to the case, the deadline for

Plaintiff to file an amended complaint should be extended to March 1, 2010 and Defendants' response to Plaintiff's Amended Complaint should be extended to April 15, 2010.

NOW, THEREFORE, the undersigned parties hereby stipulate and agree, and respectfully request that the Court enter an order as follows:

1. Plaintiff shall file its Amended Complaint on or before March 1, 2010.

2. Defendants shall file a response to the Amended Complaint on or before April 15, 2010.

IT IS SO STIPULATED.

I, Samuel M. Ward, and the ECF User whose ID and password are being used to file this Stipulation and [Proposed] Order. In compliance with General Order 45, X.B., I hereby attest that ...


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