UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
May 14, 2009
IN RE JUNIPER NETWORKS, INC. SECURITIES LITIGATION
The opinion of the court was delivered by: Honorable James Ware United States District Judge
This Document Relates To: All Actions
STIPULATION AND [PROPOSED] ORDER EXPANDING PAGE LIMITS FOR JUNIPER DEFENDANTS' OPPOSITION TO LEAD PLAINTIFF'S MOTION FOR CLASS CERTIFICATION
WHEREAS, plaintiffs filed their motion for class certification on March 2, 2009;
WHEREAS, pursuant to the Court's Order dated on March 26, 2009, defendants' opposition to plaintiff's motion for class certification to be filed on or before June 1, 2009;
WHEREAS, Civil L.R. 7-3(a) provides for a twenty-five (25) page limit on defendants' opposition brief to plaintiffs' motion for class certification;
WHEREAS, the Juniper Defendants (defined in the caption above) believe that the page limits provided by Civil L.R. 7-3(a) will not be sufficient to address critical issues raised by plaintiffs' motion for class certification;
WHEREAS, the parties met and conferred, and plaintiffs agreed to the Juniper Defendants' request that they be allowed to file an opposition brief up to forty (40) pages;
WHEREAS, the Juniper Defendants agree not to oppose a later request by Plaintiffs to expand the page limits for Plaintiffs' reply in support of their motion for class certification;
THEREFORE, the parties hereby STIPULATE and AGREE, and request that the Court order as follows:
1. The Juniper Defendants' opposition to Plaintiffs' motion for class certification may be up to forty (40) pages in length, exclusive of caption page, the table of contents, the table of authorities, declarations and exhibits; and
2. If Plaintiffs request additional pages for their reply in support of their motion for class certification, the Juniper Defendants will not oppose that request.
DATED: May 1, 2009
WILSON SONSINI GOODRICH & ROSATI, P.C. NINA F. LOCKER STEVEN GUGGENHEIM JONI OSTLER
Joni Ostler 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: 650/493-9300 650/493-6811 (fax) Counsel for the Juniper Defendants
DATED: May 1, 2009
BARBARA J. HART DAVID C. HARRISON JEANNE D'ESPOSITO LOWEY DANNENBERG COHEN & HART, P.C.
JEANNE D'ESPOSITO One North Broadway, 5th Floor White Plains, NY 10601-2310 914-733-7228 (telephone) 914-997-0035 (facsimile) Lead Counsel for Lead Plaintiff
WILLEM F. JONCKHEER SCHUBERT & REED LLP Two Embarcadero Center, Suite 1050 San Francisco, CA 94111 Telephone: 415-788-4220 Local Counsel for Lead Plaintiff
DATED May 1, 2009
PETER A. WALD PATRICK E. GIBBS DAVID M. FRIEDMAN VIVANN C. STAPP LATHAM & WATKINS LLP
DAVID M. FRIEDMAN 505 Montgomery Street, Suite 2000 San Francisco, CA 94111 Telephone: 415-391-0600 Counsel for Defendant Ernst & Young LLP
PURSUANT TO STIPULATION, IT IS SO ORDERED. AS MODIFIED:
The Juniper Defendants are GRANTED a FIVE (5) page extension to their opposition brief. The opposition brief shall not exceed 30 pages.
If needed, it is further ordered that Plaintiffs' UNITED STATES DISTRICT JUDGE reply brief is also granted a FIVE (5) page extension.
The reply brief should not exceed 20 pages.
I, Joni Ostler, am the ECF User whose identification and password are being used to file this STIPULATION AND [PROPOSED] ORDER EXPANDING PAGE LIMITS FOR JUNIPER DEFENDANTS' OPPOSITION TO LEAD PLAINTIFF'S MOTION FOR CLASS CERTIFICATION. In compliance with General Order 45.X.B, I hereby attest that Jeanne D'Esposito and David M. Friedman have concurred in this filing.
Dated: May 1, 2009
WILSON SONSINI GOODRICH & ROSATI Professional Corporation By: Joni Ostler
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