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Panasonic Corporation Panasonic Corporation of North America v. Sd-3c

February 13, 2012

PANASONIC CORPORATION PANASONIC CORPORATION OF NORTH AMERICA DR. DAN OLIVER, JEANNIE OLIVER, JOE BERNARD GROSS, SUSAN KEELIN,
WALTER KVASNIK, KOU SRIMOUNGHANCH, HUMBERTO
GONZALEZ, SAMUEL D. LEGGETT, BRIAN ALBEE, MARY LOUISE FOWLER, JOE SHAW, AND RHONDA SCHULTZ,
ON THEIR OWN BEHALVES AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED,
PLAINTIFFS,
v.
SD-3C, LLC; PANASONIC CORP.; PANASONIC CORP. OF NORTH AMERICA; TOSHIBA CORP.; TOSHIBA AMERICA ELECTRONIC COMPONENTS, INC.; AND SANDISK CORP.,
DEFENDANTS.



The opinion of the court was delivered by: Hon. Jeffrey S. White United States District Court Judge

ALDO A. BADINI (SBN 257086) 1 abadini@dl.com DEWEY & LEBOEUF LLP Post Montgomery Center One Montgomery Street, Suite 3500 San Francisco, CA 94104 Telephone: (415) 951-1120 Facsimile: (212) 632-0888 JEFFREY L. KESSLER (admitted pro hac vice) jkessler@dl.com DEWEY & LEBOEUF LLP 1301 Avenue of the Americas New York, NY 10019 Telephone: (212) 259-8000 Facsimile: (212) 259-6333 Attorneys for Defendants

[Additional Counsel Listed on Signature Page]

JOINT STIPULATION AND [PROPOSED] ORDER TO SET MOTION TO DISMISS BRIEFING SCHEDULE AND PAGE LIMITS AND TO STAY DISCOVERY

defendants Panasonic Corporation, Panasonic Corporation of North America, Toshiba Corporation, 3 (collectively, "Defendants") filed a Joint Stipulation to Extend Time Within Which to Respond to 5 Complaint Pursuant to Local Rule 6-1(a), which provided that Defendants' time to respond to an 6 amended complaint filed by Plaintiffs would be extended to include the ninetieth (90th) day after 7 the filing date of such an amended complaint; 8

WHEREAS on June 27, 2011, the indirect purchaser plaintiffs (collectively "Plaintiffs") and Toshiba America Electronic Components, Inc., SD-3C, LLC, and SanDisk Corporation 4

WHEREAS on November 23, 2011, Plaintiffs filed their First Amended Complaint;

WHEREAS, pursuant to the June 27, 2011 stipulation among the parties, the time for Defendants to respond to the First Amended Complaint was extended to February 21, 2012, which 11 is the ninetieth day after the Plaintiffs filed the First Amended Complaint; 12

IT IS HEREBY FURTHER STIPULATED BY AND BETWEEN THE PARTIES

HERETO, through their respective counsel, subject to the approval of the Court, that: (1.) Defendants may file a single joint motion to dismiss the Plaintiffs' First Amended

Complaint and a consolidated memorandum of points and authorities in support of their joint 16 motion; Plaintiffs may file a single opposition to Defendants' joint motion to dismiss; and 17

(2.) Pursuant to Local Rule 6-2(a), the time for Plaintiffs to file their opposition to

Defendants' joint motion to dismiss shall be extended to and include the forty-fifth (45th) day after 20 the date on which Defendants file their joint motion to dismiss. 21

22 reply to Plaintiffs' opposition to Defendants' joint motion to dismiss shall be extended to and 23 include the twenty-fifth (25th) day after the date on which ...


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