The opinion of the court was delivered by: The Honorable Richard Seeborg United States District Judge
ROBBINS GELLER RUDMAN & DOWD LLP DENNIS J. HERMAN (220163) Post Montgomery Center One Montgomery Street, Suite 1800 San Francisco, CA 94104 Telephone: 415/288-4545 415/288-4534 (fax) email@example.com Lead Counsel for Plaintiffs
[Additional Counsel on Signature Page]
STIPULATION AND [PROPOSED] ORDER
REGARDING FILING OF
AND RESPONSE THERETO
Lead Plaintiff Sing Pui Leung ("Leung") and Defendants Logitech International S.A., Gerald P. Quindlen and Erik Bardman hereby jointly seek entry of the following proposed schedule, and as 3 grounds therefor state as follows: 4
On October 24, 2011, the parties submitted a Stipulation and [Proposed] Consolidation Order (Dkt. No. 22) ("Stipulation") establishing deadlines for filing a consolidated complaint in this action, 6 briefing any motion directed at the pleadings, and addressing other matters pursuant to Civil 7 L.R. 23-1(b). At the October 27, 2011 hearing on Leung's motion seeking appointment as the lead 8 plaintiff in this action, the Court indicated it had reviewed and would approve the Stipulation. The Under the Stipulation, Lead Plaintiff's consolidated complaint would be due to be filed on December 27, 2011, which is 60 days after entry of the Court's order appointing Leung as the lead 12 plaintiff for this action. See Stipulation, ¶11; Dkt. No. 26. Due to the departure of one of the 13 attorneys handling this matter on behalf of Lead Counsel, and other staffing disruptions caused by 14 the holidays, Lead Counsel, with the approval of the Lead Plaintiff, has sought Defendants' 15 agreement to a brief extension of the filing deadline, to which they have agreed. Accordingly, the 16 parties hereby submit a revised schedule which modifies ¶11 of the prior Stipulation to establish a 17
THEREFORE, it is hereby stipulated by the parties, subject to the approval of the Court, that
Lead Plaintiff shall file a consolidated complaint on or before January 9, 2012. The consolidated 20 complaint shall be the operative complaint and shall supersede all complaints filed in this action. 21
Defendants shall respond to the consolidated complaint within sixty (60) days after service. If 22 defendants file any motions directed at the consolidated complaint, the opposition and reply briefs 23 shall be filed within 60 days and 30 days, respectively, of that response. Court has not yet entered the Stipulation.
January 9, 2012 deadline for Lead Plaintiff to file a consolidated complaint.
I, Dennis J. Herman, am the ECF User whose ID and password are being used to file this STIPULATION AND [PROPOSED] ORDER REGARDING FILING OF COMPLAINT AND 22 RESPONSE THERETO. In compliance with General Order 45, X.B., I hereby attest that Ignacio E. 23 Salceda has concurred in this filing. 24