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In re Juniper Networks

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


July 15, 2009

IN RE JUNIPER NETWORKS, INC. SECURITIES LITIGATION
THIS DOCUMENT RELATES TO:
THE NEW YORK CITY EMPLOYEES' RETIREMENT SYSTEM, THE TEACHERS' RETIREMENT SYSTEM OF THE CITY OF NEW YORK, THE NEW YORK CITY FIRE DEPARTMENT PENSION FUND, THE NEW YORK CITY ) POLICE PENSION FUND, THE NEW YORK CITY POLICE SUPERIOR OFFICERS' VARIABLE SUPPLEMENTS FUND, THE NEW YORK CITY POLICE OFFICERS' VARIABLE SUPPLEMENTS FUND, THE NEW YORK CITY FIREFIGHTERS' VARIABLE SUPPLEMENTS FUND, AND THE NEW YORK CITY FIRE OFFICERS' VARIABLE SUPPLEMENTS FUND, AND THE NEW YORK CITY TEACHERS' RETIREMENT SYSTEM OF THE CITY OF NEW YORK VARIABLE ANNUITY PROGRAM, PLAINTIFFS,
v.
LISA C. BERRY, DEFENDANT.

The opinion of the court was delivered by: Honorable Patricia V. Trumbull

ALL ACTIONS

STIPULATION AND [PROPOSED] ORDER HEARING THE MOTION FOR 17 SHORTENING TIME FOR PROTECTIVE ORDER REGARDING DEPOSITIONS

WHEREAS, concurrently with filing this Stipulation, defendant Juniper Networks, Inc. and non-parties Jodi Sutton, Ann Laporte and Ray Martinelli will file a Motion for Protective Order Regarding Depositions ("Motion for Protective Order");

WHEREAS, the issue raised in the Motion for Protective Order is discrete and the parties would like to have it heard on the same date as the previously-scheduled hearing on Lead Plaintiffs' pending Motion to Compel Juniper Networks, Inc. to Produce Restatement Communications (Dkt. No. 280 in Case No. 06-04327);

WHEREAS, in addition, the Motion for Protective Order concerns certain depositions that the lead plaintiffs plan to take in August, and the parties need a decision on the Motion for Protective Order sooner than the standard 35-day notice so they can adequately plan in advance of the planned depositions;

NOW THEREFORE, the parties stipulate, and request that the Court order:

1. Any opposition(s) to the Motion for Protective Order shall be filed by July 22, 2009;

2. Any reply in support of the Motion for Protective Order shall be filed by July 28, 2009;

3. A hearing on the Motion for Protective Order shall be held on August 4, 2009 at 10:00 a.m.

IT IS SO STIPULATED.

DATED: July 13, 2009

WILSON SONSINI GOODRICH & ROSATI, P.C. NINA F. LOCKER STEVEN GUGGENHEIM JONI OSTLER 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: 650/493-9300 650/493-6811 (fax) Counsel for Defendant Juniper Networks, Inc., and Non-Party Witnesses Jodi Sutton, Anne Laporte and Ray Martinelli

DATED: July 13, 2009

BARBARA J. HART DAVID C. HARRISON LOWEY DANNENBERG COHEN & HART, P.C. DAVID C. HARRISON One North Broadway, 5th Floor White Plains, NY 10601-2310 914-733-7228 (telephone) 914-997-0035 (facsimile) Lead Counsel for Lead Plaintiff

DATED July 13, 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

DATED July 13, 2009

MELINDA HAAG JAMES N. KRAMER NANCY E. HARRIS REBECCA F. LUBENS ORRICK, HERRINGTON & SUTCLIFFE LLP NANCY E. HARRIS The Orrick Building 405 Howard Street San Francisco, CA 94105-2669 Telephone: 415-773-5700 Counsel for Defendant Lisa C. Berry

IT IS SO ORDERED.

20090715

© 1992-2009 VersusLaw Inc.



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