UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION
November 28, 2011
THOMAS E. HARPER AND DIANE KEENE,
INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED,
NANCY L. KNOWLTON, G.A. SMART TECHNOLOGIES, INC., DAVID A. MARTIN, FITCH, SALIM NATHOO, ARVIND
SODHANI, INTEL CORPORATION, APAX ALLEGATIONS PARTNERS, MORGAN STANLEY & CO.
INC., DEUTSCHE BANK AG, AND RBC DOMINION SECURITIES INC, DEFENDANTS.
The opinion of the court was delivered by: The Honorable Saundra Brown Armstrong United States District Court
Sara B. Brody (SBN 130222) SIDLEY AUSTIN LLP 555 California Street, 19th Floor San Francisco, California 94104 Telephone: (415) 772-1200 Facsimile: (415) 772-7400 email@example.com Andrew W. Stern (to be admitted pro hac) SIDLEY AUSTIN LLP 87 Seventh Avenue New York, NY 10019 Telephone: (212) 839-5300 Facsimile: (212) 839-5599 firstname.lastname@example.org Attorneys for Defendants SMART Technologies Inc., David A. Martin, Nancy L. Knowlton, G.A. Fitch, Salim Nathoo, Arvind Sodhani, and Apax Partners
[Counsel for Additional Parties Listed on Signature Page]
Assigned to: Hon. Saundra Brown Armstrong
STIPULATION EXTENDING TIME FOR REMAND AND DEFENDANTS' MOTION BRIEFING ON PLAINTIFFS' MOTION TO ALTERNATIVE DISMISS OR STAY THIS TO TRANSFER THIS ACTION OR IN THE ACTION AND STRIKE THE CLASS
Martin, Nancy L. Knowlton, G.A. Fitch, Salim Nathoo, Arvind Sodhani, Intel Corporation, Apax 3 RBC Dominion Securities Inc. ("Defendants"), and Plaintiffs Thomas E. Harper and Dianne Keene 5 ("Plaintiffs"), by and through their respective counsel of record, hereby submit the following 6 stipulation. 7 8 the alternative Dismiss or Stay this action and Strike the Class Allegations ("Defendants' Motion"); 9 WHEREAS, on November 9, 2011, Plaintiffs filed a Motion to Remand this action ("Plaintiffs' Motion"); 12
WHEREAS, the Local Rules for the Northern District of California require that, unless 14 otherwise ordered, Defendants' Motion would be fully briefed by November 29, 2011 and that 15 WHEREAS, Plaintiffs and Defendants have conferred about establishing a more flexible 17 schedule for completing briefing on their respective Motions; 18 19 stipulate as follows: 20
any Court order. 26 27 28
Pursuant to Civil Local Rule 6-1(a), Defendants SMART Technologies Inc., David A. Partners, Morgan Stanley & Co. LLC (f/k/a Morgan Stanley & Co. Inc.), Deutsche Bank AG, and 4
WHEREAS, on November 8, 2011, Defendants filed a Motion to Transfer this action or in WHEREAS, Plaintiffs intend to oppose Defendants' Motion;
WHEREAS, Defendants intend to oppose Plaintiffs' Motion;
Plaintiffs' Motion would be fully briefed by November 30, 2011;
THEREFORE, Plaintiffs and Defendants, by and through their respective counsel, hereby
1. Plaintiffs and Defendants shall file their respective opposition papers in response to the Motions by December 2, 2011.
2. Plaintiffs and Defendants shall file their respective reply papers in support of the Motions by December 16, 2011.
The requested extension will not alter the date of any event or any deadline already fixed by SIGNATURE ATTESTATION Pursuant to General Order No. 45(X)(B), I hereby attest that I have on file written permission 3 to sign this joint motion from all parties whose signatures are indicated by a conformed signature 4 (/s/) within this e-filed document. 5
/s/ Sara B. Brody
PURSUANT TO THE PARTIES' STIPULATION, IT IS SO ORDERED.
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