The opinion of the court was delivered by: The Honorable Jeremy Fogel United States District Court Judge
STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER
Plaintiff Walter Hamilton ("Hamilton"), defendants Kevin Bushby, Michael J. Fister, Donald L. Lucas, R. L. Smith McKeithen, James S. Miller, Jr., William Porter, Alberto Sangiovanni-Vincentelli, George M. Scalise, John B. Shoven, Roger S. Siboni, John A.C. Swainson, Lip-Bu Tan and nominal defendant Cadence Design Systems, Inc. (collectively, the "Defendants"), by and through their respective counsel, stipulate as follows:
WHEREAS, Hamilton served the Verified Shareholder Derivative Complaint for Breach of Fiduciary Duty, Waste of Corporate Assets, Professional Negligence, Breach of Contract, and Unjust Enrichment (the "Complaint") on all the Defendants;
WHEREAS, Defendants currently are required to answer, move, or otherwise
WHEREAS, the initial Case Management Conference in this case is scheduled to respond to the Complaint by August 16, 2010;
WHEREAS, the parties believe that meet and confer discussions among counsel, proceed on July 16, 2010, at 10:30 a.m., before U.S. District Judge Jeremy Fogel; and the initial Case Management Conference with the Court, will be more meaningful and productive if the Case Management Conference is delayed until after the filing of Defendants' answers or responses to the Complaint;
WHEREAS, the parties agree that it would be best to extend the date of the Case Management Conference by 60 days;
THEREFORE, IT IS HEREBY STIPULATED AND REQUESTED, by and among the parties, acting through their respective attorneys of record, on the basis of the foregoing, that:
1. The Court continue the Case Management Conference from July 16, 2010 to September 16, 2010, or as soon thereafter as the Court's calendar permits.
THE WEISER LAW FIRM, P.C. Kathleen A. Herkenhoff Attorneys for Plaintiff Walter Hamilton
GIBSON, DUNN & CRUTCHER LLP Ethan D. Dettmer Attorneys for Nominal Defendant Cadence Design Systems, Inc.
SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP Garrett J. Waltzer Attorneys for Defendants Michael J. Fister, Donald L. Lucas, Alberto Sangiovanni-Vincentelli, George M. Scalise, John B. Shoven, ...