REVISED STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND AND CONTINUING CASE MANAGEMENT CONFERENCE
WHEREAS, Plaintiff David Smith filed a Complaint against Defendants TeleNav, Inc., H.P. Jin, Douglas S. Miller, Shawn Carolan, Samuel Chen, Hon Jane Chiu, Soo Boon Koh, Joseph M. Zaelit, J.P. Morgan Securities Inc., and Deutsche Bank Securities Inc. on September 2, 2010 (the "Action");
WHEREAS, a number of the Defendants were served with the summons and complaint;
WHEREAS, the undersigned parties anticipate that additional complaints may be filed, and a Lead Plaintiff and Lead Counsel will need to be appointed;
WHEREAS, the undersigned parties anticipate that, following the appointment of Lead Plaintiff, an amended complaint will be filed;
WHEREAS, the case management conference is currently scheduled before this Court on December 17, 2010 at 10:00 a.m.;
NOW, THEREFORE, in the interest of judicial economy and good cause showing, the parties, by and through their undersigned counsel of record, hereby agree and stipulate, and the Court hereby orders, as follows:
1. Defendants need not respond to the complaint filed September 2, 2010;
2. After the appointment of a Lead Plaintiff and Lead Counsel, Defendants and Lead Plaintiff shall meet and confer to determine a schedule for the filing of an amended complaint, and Defendants' response thereto. The parties will file a stipulated schedule for approval by the Court; and
3. The case management conference currently scheduled for December 17, 2010 at 10:00 a.m. shall be continued until June 10, 2011 at 10:00 a.m. The parties shall file one joint case management statement seven (7) days prior to June 10, 2011.
The Parties respectfully request that the Court enter an Order approving this Stipulation.
Dated: October 4, 2010 WILSON SONSINI GOODRICH &ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304 Telephone: (650) 493-9300 Facsimile: (650) 493-6811 Caz Hashemi Attorneys for Defendants TeleNav, Inc., H.P. Jin, Douglas S. Miller, Shawn Carolan, Samuel Chen, Hon Jane Chiu, Soo Boon Koh, and Joseph M. Zaelit
Dated: October 4, 2010 ROBBINS GELLER RUDMAN &DOWD LLP Post Montgomery Center One Montgomery Street, Suite 1800 San Francisco, CA 94104 Telephone: (415) 288-4545 Facsimile: (415) 288-4534 ...