The opinion of the court was delivered by: Edward J. Davila United States District Judge
ABRAHAM, FRUCHTER & TWERSKY, LLP 2 IAN D. BERG (Bar No. 263586) TAKEO A. KELLAR (Bar No. 234470) 3 12526 High Bluff Drive, Suite 300 San Diego, CA 92130 4 Tel: (858) 792-3448 Fax: (858) 792-3449 5 email@example.com firstname.lastname@example.org 6 Lead Counsel and Counsel For Lead Plaintiff 7 for Oklahoma Firefighters Pension and Retirement System 8 9
STIPULATION AND [PROPOSED] ORDER REGARDING REVISED SCHEDULING OF CONSOLIDATED COMPLAINT
"Defendants") hereby stipulate as follows: 4 WHEREAS, on November 2, 2011, the Lead Plaintiff and Defendants submitted to the Court a Stipulation and [Proposed] Order setting forth a schedule for the timing of a consolidated 6 complaint and motion to dismiss; 7
Lead Plaintiff Oklahoma Firefighters Pension and Retirement System ("Lead Plaintiff") 2 and Defendants Finisar Corp., Jerry S. Rawls, Eitan Gertel, and Kurt Adzema (collectively, 3
WHEREAS, on November 7, 2011, the Court entered an Order accepting the proposed 5 8 schedule as follows: Lead Plaintiff shall file a consolidated complaint before January 13, 2012; 9 Defendants shall move to dismiss the consolidated complaint on or before March 13, 2012; Lead 10 Plaintiff shall file its opposition to the motion to dismiss on or before April 16, 2012; Defendants 11 shall file their reply in support of the motion to dismiss on or before May 11, 2012; and the 12 Hearing date on the motion to dismiss the consolidated complaint is set for June 1, 2012, at 9:00 13 a.m., with a Case Management Conference to be held on the same day; 14
WHEREAS, Lead Plaintiff is experiencing an unexpected delay in the course of its 15 investigation, which includes an investigation being conducted in the People's Republic of 16 China; and 17
WHERAS, Lead Plaintiff believes, and Defendants do not object, that it would be in the 18 best interests of efficiency and Judicial economy to delay slightly the time for Lead Plaintiff to 19 file a consolidated complaint, and to adjust the motion to dismiss briefing schedule without 20 causing undue delay in the Hearing of the motion by the Court, 21
IT IS HEREBY STIPULATED THAT:
1. The time for Lead Plaintiff to file a consolidated complaint shall be extended from January 13, 2012 to January 20, 2012.
3. The time for Defendants to move to dismiss the consolidated complaint shall be 25 extended from March 13, 2012 to March 16, 2012, with the motion noticed for a hearing date on 26 June 1, 2012, at 9:00 a.m., as previously ordered by the Court.
4. Lead Plaintiff shall file its opposition to the motion to dismiss on or before April 16, 2012, as previously ordered by the Court.
5. Defendants shall file their reply in support of the motion to dismiss on or before May 11, 2012, as previously ordered by the Court. 3
6. The Case Management Conference will remain set for June 1, 2012, and a Joint Case Management Conference Statement shall be filed on or before May 25, ...