Candelore v. LDK Solar Co., Ltd. et al

Filing 122

STIPULATION AND ORDER MODIFYING BRIEFING AND HEARING SCHEDULE ON LEAD PLAINTIFF'S MOTION FOR CLASS CERTIFICATION (whalc2, COURT STAFF) (Filed on 9/2/2008)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LATHAM & WATKINS LLP James J. Farrell (Bar No. 166595) james.farrell@lw.com 633 West Fifth Street, Suite 4000 Los Angeles, California 90071-2007 Telephone: (213) 485-1234 Facsimile: (213) 891-8763 LATHAM & WATKINS LLP Philip J. Wang (Bar No. 218349) philip.wang@lw.com Raymond A. Gallenberg (Bar No. 239484) ray.gallenberg @lw.com 140 Scott Drive Menlo Park, California 94025 Telephone: (650) 328-4600 Facsimile: (650) 463-2600 Attorneys for Defendants COHEN, MILSTEIN, HAUSFELD & TOLL, P.L.L.C. Steven J. Toll Herbert E. Milstein Mark S. Willis Joshua S. Devore Matthew B. Kaplan hmilstein@cmht.com 1100 New York Avenue, N.W. Suite 500, West Tower Washington, DC 20005 Telephone: (202) 408-4600 Facsimile: (202) 408-4699 COHEN, MILSTEIN, HAUSFELD & TOLL, P.L.L.C. Michael Lehmann mlehmann@cmht.com One Embarcadero Center Suite 526 San Francisco, CA 94111 Telephone: (415) 623-2048 Facsimile: (415) 433-5994 Lead Counsel for the Proposed Class UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA In re LDK SOLAR SECURITIES LITIGATION ____________________________________ This Document Relates To: ALL ACTIONS. MASTER FILE NO. C-07-05182-WHA STIPULATION AND [PROPOSED] ORDER MODIFYING BRIEFING AND HEARING SCHEDULE ON LEAD PLAINTIFF'S MOTION FOR CLASS CERTIFICATION [Civil L.R. 7-1(a)] STIP. AND [PROPOSED] ORDER MODIFYING BRIEFING AND HEARING SCHED. ON LEAD PL.'S MOT. FOR CLASS CERT. MASTER FILE NO. C-07-5182-WHA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 WHEREAS, pursuant to the Court's June 3, 2008 Case Management Order, Lead Plaintiff's motion for class certification must be filed on August 28, 2008; WHEREAS, Lead Plaintiff's motion for class certification is currently scheduled to be heard on October 2, 2008, at 8:00 a.m.; WHEREAS, the parties have, in good faith, met and conferred regarding the current briefing and hearing schedule, and agree that class-related discovery is desired and that more time is needed to conduct such discovery; NOW, THEREFORE, the parties hereby stipulate that: 1. Lead Plaintiff shall file his motion for class certification on August 28, 2008, the date set in the current Case Management Order. 2. Defendants shall file any opposition to Lead Plaintiff's motion for class certification no later than September 29, 2008. 3. Lead Plaintiff shall file any reply in support of his motion for class certification no later than October 27, 2008. 4. The hearing on Lead Plaintiff's motion for class certification shall occur on November 13, 2008, at 8:00 a.m. 1 STIP. AND [PROPOSED] ORDER MODIFYING BRIEFING AND HEARING SCHED. ON LEAD PL.'S MOT. FOR CLASS CERT. MASTER FILE NO. C-07-5182-WHA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: August 28, 2008 LATHAM & WATKINS LLP Raymond A. Gallenberg By /S/ Attorneys for Defendants Dated: August 28, 2008 COHEN,M MILSTEIN, HAUSFELD, & TOLL, P.L.L.C. Matthew B. Kaplan By /S/ Lead Counsel for Lead Plaintiff Shahpour Javidzad and the Proposed Class I, Raymond A. Gallenberg, am the ECF User whose ID and password are being used to file this Stipulation and [Proposed] Order Modifying Briefing and Hearing Schedule on Lead Plaintiff's Motion for Class Certification. In compliance with General Order 45, X.B., I hereby attest that Matthew B. Kaplan has concurred in this filing. 2 STIP. AND [PROPOSED] ORDER MODIFYING BRIEFING AND HEARING SCHED. ON LEAD PL.'S MOT. FOR CLASS CERT. MASTER FILE NO. C-07-5182-WHA 1 2 3 4 5 6 7 8 9 10 11 12 2008. 2. [PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED: 1. Lead Plaintiff shall file his motion for class certification on August 28, Defendants shall file any opposition to Lead Plaintiff's motion for class certification no later than September 29, 2008. 3. Lead Plaintiff's shall file any reply in support of his motion for class certification no later than October 27, 2008. 4. The hearing on Lead Plaintiff's motion for class certification shall occur on November 13, 2008, at 8:00 a.m. September 2 Dated: __________________, 2008 IT IS SO ORDERED UNIT ED S DISTRICT TE C TA RT U O 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 S _______________________________________ ER N William The Honorable DISTRICT OF CH. Alsup United States District Judge A STIP. AND [PROPOSED] ORDER MODIFYING BRIEFING AND HEARING SCHED. ON LEAD PL.'S MOT. FOR CLASS CERT. MASTER FILE NO. C-07-5182-WHA LI FO Judge W illiam A lsup R NIA O IT IS S ED ORDER NO RT H

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