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Robert A. Scandlon, Jr., On Behalf of Himself and All Others Similarly Situated v. Blue Coat Systems

December 22, 2011

ROBERT A. SCANDLON, JR., ON BEHALF OF HIMSELF AND ALL OTHERS SIMILARLY SITUATED,
PLAINTIFF,
v.
BLUE COAT SYSTEMS, INC., BRIAN M. NESMITH AND GORDON C. BROOKS, DEFENDANTS.



The opinion of the court was delivered by: Richard Seeborg United States District Judge

*E-Filed 12/22/11*

STIPULATION AND [PROPOSED] ORDER (1) SETTING DATE FOR FILING OF AMENDED CLASS ACTION COMPLAINT (2) ESTABLISHING BRIEFING SCHEDULE FOR RESPONSIVE MOTION(S) AND (3) CONTINUING CASE MANAGEMENT CONFERENCE AS MODIFIED BY THE COURT CLASS ACTION

2 of the International Brotherhood of Teamsters ("Lead Plaintiff" or "Inter-Local Pension Fund") 3 and defendants Blue Coat Systems, Inc., Brian M. NeSmith and Gordon C. Brooks 4 Court approval, as follows concerning the filing of an amended class complaint ("Amended 6 Management Conference scheduled for February 2, 2012. 8 10 complaint ("Initial Complaint") on August 30, 2011 (Docket Number ("Dkt.") 1), alleging that 11

WHEREAS the Initial Complaint alleged claims arising under the Private Securities Litigation Reform Act of 1995 ("PSLRA"); 14 Lead Plaintiff and Lead Counsel (Dkt. 13 and 23); 17 18 motion appointing it Lead Plaintiff and appointing Spector Roseman Kodroff & Willis, P.C. as 19 lead counsel and Berman DeValerio as liaison counsel (Dkt. 41); 20

WHEREAS counsel for Lead Plaintiff and Defendants have conferred and the parties 21 have reached agreement, subject to Court approval, as to a schedule for the filing by Lead 22 Defendants of motions to dismiss the Amended Complaint; 24 25 economy to continue the scheduled Case Management Conference, currently set for February 2, 26 2012, until after the Court has ruled on all motions filed in response to the Amended Complaint; 27 28

Lead Plaintiff the Inter-Local Pension Fund of the Graphic Communications Conference ("Defendants"), by and through their respective counsel hereby recite and stipulate, subject to 5 Complaint"), the briefing schedule for any responsive motions and the continuance of the Case 7

RECITALS

WHEREAS plaintiff Robert Scandlon ("Scandlon") filed a securities class action Defendants violated federal securities laws; 12

WHEREAS on October 31, 2011, in accordance with procedures set forth in the PSLRA, Scandlon and the Inter-Local Pension Fund each filed competing motions to Appoint 16

WHEREAS, on December 12, 2011, the Court granted the Inter-Local Pension Fund's Plaintiff of an amended class action complaint ("Amended Complaint") and the filing by 23

WHEREAS the parties further agree that it will serve the interests of justice and judicial

[PROPOSED] ORDER

IT IS HEREBY ORDERED that:

1. Lead Plaintiff the Inter-Local Pension Fund of the Graphic Communications Conference of the International Brotherhood of Teamsters shall file and serve the ...


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