Soto v. Origin Materials, Inc. et al

Filing 88

STIPULATION and ORDER signed by Senior District Judge William B. Shubb on 11/22/24, ORDERING that Defendants shall file a motion to dismiss the SAC no later than 12/19/24. Lead Plaintiff shall file an opposition to the motion to dismiss the SAC no l ater than 1/21/25. Defendants shall file a reply brief in support of the motion to dismiss the SAC no later than 2/4/25. Hearing on the motion is set for 2/18/25 at 1:30 p.m. in Courtroom 5. The Scheduling Conference is RESET for 4/7/2025 at 01:30 PM in Courtroom 5 (WBS) before Senior District Judge William B. Shubb. A Joint Status Report shall be filed no later than 3/24/25. (Salmeron, A)

BORIS FELDMAN, State Bar No. 128838
[e-mail]
DORU GAVRIL, State Bar No. 282309
[e-mail]
CARL HUDSON, State Bar No. 317201
[e-mail]
REBECCA LOCKERT, State Bar No. 348810
[e-mail]
FRESHFIELDS US LLP
855 Main Street
Redwood City, CA 94063
Telephone: [phone]
Attorneys for Defendants Origin Materials, Inc.,
Richard J. Riley, and John Bissell
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
In re ORIGIN MATERIALS, INC.
SECURITIES LITIGATION

Case No.: 2:23-cv-01816-WBS-JDP

_______________________________________

JOINT STIPULATION AND ORDER FOR
BRIEFING SCHEDULE FOR MOTION TO
DISMISS SECOND AMENDED COMPLAINT
FOR VIOLATIONS OF THE FEDERAL
SECURITIES LAWS

ALL ACTIONS CONSOLIDATED FROM:
Antonio F. Soto, individually
and on behalf of all others
similarly situated,
Plaintiff,
v.
Origin Materials, Inc., Richard
J. Riley, and John Bissell,
Defendants.

STIPULATION AND ORDER RE BRIEFING SCHEDULE

WHEREAS, on October 29, 2024, the Court issued an Order (ECF
No. 82) granting Defendants’ Motion to Dismiss (ECF No. 69)
Plaintiff’s Corrected Amended Complaint for Violations of the
Federal Securities Laws (ECF No. 61) in the above-captioned case
with leave to amend within 20 days;
WHEREAS, on November 18, 2024, Lead Plaintiff filed a Second
Amended Complaint for Violations of the Federal Securities Laws
(the “SAC”) (ECF No. 85);
WHEREAS, Defendants intend to move to dismiss the SAC;
WHEREAS, the only prior extension sought in this case was the
one ordered by the Court, for further time to respond to the
initial complaints (ECF Nos. 25 (stipulation), 28 (order));
NOW

THEREFORE,

IT

IS

SO

STIPULATED,

by

and

between

the

undersigned, subject to approval of this Court, that the briefing
schedule for the motion to dismiss the SAC, will be as follows:
1. Defendants shall file a motion to dismiss the SAC no
later than December 19, 2024.
2. Lead Plaintiff shall file an opposition to the motion to
dismiss the SAC no later than January 21, 2025.
3. Defendants shall file a reply brief in support of the
motion to dismiss the SAC no later than February 4, 2025.

STIPULATION AND ORDER RE BRIEFING SCHEDULE

4. Pursuant

to

the

PSLRA,

“all

discovery

and

other

proceedings shall be stayed during the pendency of any
motion to dismiss, unless the court finds upon the motion
of any party that particularized discovery is necessary,”
15

U.S.C.

request

§

that

78u-4(b)(3)(B).
the

Court

The

vacate

Parties

(or

respectfully

continue,

in

its

discretion) the related deadlines (ECF No. 77):
a. December

2,

2024:

Last

day

to

file

Joint

Status

Report.
b. December 12, 2024: Scheduling Conference.

Dated:

11/21/24

FRESHFIELDS US LLP
/s/ Boris Feldman
BORIS FELDMAN
DORU GAVRIL
CARL HUDSON
REBECCA LOCKERT
855 Main Street
Redwood City, CA 94063
Telephone: [phone]
[e-mail]
[e-mail]
carl.hudson&freshfields.com
[e-mail]

_

Attorneys for Defendants Origin
Materials, Inc., Richard J. Riley, and
John Bissell
Dated:

11/21/24

BRAGAR EAGEL & SQUIRE P.C
/s/ Marion C. Passmore, Esq.
Marion C. Passmore (SBN #228474)
580 California Street, Suite 1200
San Francisco, CA 94104
[phone] (phone)
[phone] (fax)
[e-mail]

STIPULATION AND ORDER RE BRIEFING SCHEDULE

Liaison Counsel for Lead Plaintiff,
Lead Counsel, and the Proposed Class
BERNSTEIN LIEBHARD LLP
Stanley D. Bernstein
Michael S. Bigin
Stephanie M. Beige
10 East 40th Street
New York, NY 10016
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Lead Counsel for the Lead Plaintiff and
the Proposed Class

Pursuant to the parties' stipulation, IT IS SO ORDERED:
1. Defendants shall file a motion to dismiss the SAC no
later than December 19, 2024;
2. Lead Plaintiff shall file an opposition to the motion to
dismiss the SAC no later than January 21, 2025;
3. Defendants shall file a reply brief in support of the
motion to dismiss the SAC no later than February 4, 2025;
4. Hearing on the motion is set for February 18, 2025 at
1:30 p.m. in Courtroom 5;
5. Pursuant

to

the

PSLRA,

“all

discovery

and

other

proceedings shall be stayed during the pendency of any
motion to dismiss, unless the court finds upon the motion
of any party that particularized discovery is necessary,”
15 U.S.C. § 78u-4(b)(3)(B).
6. The Scheduling Conference is reset for April 7, 2025
1:30 p.m. in Courtroom 5; and

STIPULATION AND ORDER RE BRIEFING SCHEDULE

at

7. A Joint Status Report shall be filed no later than March
24 2025 in accordance with the Court's Order Re: Status
(Pretrial Scheduling) Conference filed
(Docket No. 3).
Dated:

November 22, 2024

STIPULATION AND ORDER RE BRIEFING SCHEDULE

August 25, 2023