Case 1:24-cv-07046-PK Document 32 Filed 01/22/25 Page 1 of 3 PageID #: 489 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK In re: Iris Energy Limited Securities Litigation 1:24-cv-7046 (PK) STIPULATION AND ORDER SETTING PLEADING AND BRIEFING SCHEDULE Lead Plaintiff Rick Bunney (“Lead Plaintiff”) and Defendants IREN Limited (f/k/a Iris Energy Limited), Daniel Roberts, Williams Roberts, and Belinda Nucifora (“Defendants,” and together with Lead Plaintiff, the “Parties”), by and through their undersigned counsel, hereby stipulate and agree as follows: WHEREAS, on October 7, 2024, Paul Williams-Israel commenced the above- captioned putative class action by filing a complaint (the “Complaint”) against Defendants asserting claims pursuant to Sections 10(b) and 20(a) of the Exchange Act (15 U.S.C. §§ 78j(b) and 78t(a)) and Rule 10b-5 promulgated thereunder by the SEC (17 C.F.R. § 240.10b-5) (ECF No. 1); WHEREAS, on October 15, 2024, Defendants moved the Court for “an adjournment of any deadline to answer or otherwise respond to the Complaint until after the Court appoints a lead plaintiff and lead counsel” (the “Motion for Extension of Time to Answer”), with the consent of Paul Williams-Israel (ECF No. 9); WHEREAS, on October 21, 2024, the Court granted Defendants’ Motion for Extension of Time to Answer and ordered that: “Within fourteen (14) days of an order by the Court appointing a lead plaintiff and lead counsel, the parties are directed to file a joint Case 1:24-cv-07046-PK Document 32 Filed 01/22/25 Page 2 of 3 PageID #: 490 proposed schedule for the filing of any consolidated or amended complaint and for any anticipated motion to dismiss the operative complaint”; WHEREAS, on January 7, 2025, the Court issued an order appointing Rick Bunney as Lead Plaintiff, and Glancy Prongay & Murray LLP and Holzer & Holzer, LLC as Co-Lead Counsel (ECF No. 30); WHEREAS, on January 15, 2025, the Parties met and conferred and agreed to a schedule for the filing of a consolidated amended complaint and a briefing schedule for Defendants’ anticipated motion to dismiss; and WHEREAS, the Parties’ negotiated schedule will not otherwise affect the schedule of the case, as discovery is stayed pursuant to the Private Securities Litigation Reform Act and there are no other events or deadlines currently scheduled; NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE, by and through their undersigned counsel, and subject to this Court’s approval: 1. Lead Plaintiff shall file a consolidated amended complaint on or before March 24, 2025. 2. Defendants shall respond to the consolidated amended complaint, by filing a motion to dismiss or otherwise, on or before May 23, 2025. 3. Lead Plaintiff shall file an opposition to Defendants’ motion to dismiss, if any, on or before July 22, 2025. 4. Defendants shall file a reply in support of their motion to dismiss, if any, on or before September 5, 2025. 2 Case 1:24-cv-07046-PK Document 32 Filed 01/22/25 Page 3 of 3 PageID #: 491 Respectfully submitted this twenty-first day of January, 2025. GLANCY PRONGAY & MURRAY LLP DAVIS POLK & WARDWELL LLP By: /s Gregory B. Linkh By: /s Edmund Polubinski Gregory B. Linkh Edmund Polubinski 230 Park Ave. Suite 358 Paulina Perlin New York, New York 10169 450 Lexington Avenue (212) 682 5340 New York, New York 10017 glinkh@glancylaw.com (212) 450-4000 edmund.polubinski@davispolk.com Leanne Heine Solish paulina.perlin@davispolk.com Charles H. Linehan 1925 Century Park East, Suite 2100 Los Angeles, CA 90067 Mari Grace (310) 201-9150 1050 17th Street, NW lsolish@glancylaw.com Washington, DC 20036 clinehan@glancylaw.com (202) 962-7020 mari.grace@davispolk.com HOLZER & HOLZER, LLC Corey D. Holzer 211 Perimeter Center Parkway, Suite 1010 Attorney for Defendants IREN Limited, Atlanta, Georgia 30346 Daniel Roberts, William Roberts, and (770) 392-0090 Belinda Nucifora cholzer@holzerlaw.com Co-Lead Counsel for Lead Plaintiff Rick Bunney IT IS SO ORDERED. January 22 Dated:______________, 2025 Peggy Kuo New York, New York Hon. Peggy Kuo United States Magistrate Judge 3