Hu v. Cadence Design Systems, Inc et al

Filing 75

STIPULATION AND ORDER Enlarging Time to Answer First Amended Complaint to 4/30/10. (tdm, COURT STAFF) (Filed on 3/16/2010)

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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 Gibson, Dunn & Crutcher LLP GIBSON, DUNN & CRUTCHER LLP TIMOTHY K. ROAKE, SBN 99539 troake@gibsondunn.com SALLY J. BERENS, SBN 218880 sberens@gibsondunn.com 1881 Page Mill Road Palo Alto, California 94304 Telephone: (650) 849-5300 Facsimile: (650) 849-5333 ETHAN D. DETTMER, SBN 196046 edettmer@gibsondunn.com MATTHEW S. KAHN, SBN 261679 mkahn@gibsondunn.com 555 Mission Street, Suite 3000 San Francisco, California 94105 Telephone: (415) 393-8200 Facsimile: (415) 393-8306 Attorneys for Defendants CADENCE DESIGN SYSTEMS, INC., MICHAEL J. FISTER, KEVIN S. PALATNIK, WILLIAM PORTER and KEVIN BUSHBY UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION In re CADENCE DESIGN SYSTEMS, INC. SECURITIES LITIGATION ________________________________________ CASE NO. C-08-4966 CLASS ACTION STIPULATION TO ENLARGE TIME TO ANSWER FIRST AMENDED COMPLAINT This Document Relates To: ALL ACTIONS. STIPULATION TO ENLARGE TIME TO ANSWER FIRST AMENDED COMPLAINT CASE NO. C-08-4966 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 Gibson, Dunn & Crutcher LLP WHEREAS, the initial complaint in this action was filed on October 29, 2008; WHEREAS, on March 4, 2009, the Court entered an Order consolidating three related cases, appointing Alaska Electrical Pension Fund as the lead plaintiff ("Lead Plaintiff"), and approving the selection of Lead Counsel; WHEREAS, on April 24, 2009, Lead Plaintiff filed a consolidated complaint against defendants Cadence Design Systems, Inc., Michael J. Fister, Kevin S. Palatnik, William Porter, and Kevin Bushby ("Defendants," and, collectively with Lead Plaintiff, the "Parties"); WHEREAS, on September 11, 2009, the Court entered an order dismissing the consolidated complaint without prejudice; WHEREAS, on October 13, 2009, Lead Plaintiff filed an amended consolidated complaint (the "First Amended Complaint"); WHEREAS, on November 20, 2009, Defendants filed a motion to dismiss the First Amended Complaint; WHEREAS, on March 2, 2010, the Court entered an order denying Defendants' motion to dismiss the First Amended Complaint; WHEREAS, pursuant to Federal Rule of Civil Procedure 12(a)(4)(A), Defendants are required to serve a responsive pleading within 14 days of the Court's order, in this case, March 16, 2010; WHEREAS, Defendants, in light of the length of the Complaint, have requested an agreement from Plaintiffs to extend the date by which Defendants' Answer must be filed; WHEREAS, the parties, through their respective counsel, have met and conferred and agree that the date by which Defendants must file an Answer to the First Amended Complaint shall be extended to April 30, 2010; and WHEREAS, the stipulated extension will not alter the date of any event or deadline already fixed by Court order; /// /// /// /// 1 STIPULATION TO ENLARGE TIME TO ANSWER FIRST AMENDED COMPLAINT CASE NO. C-08-4966 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 Gibson, Dunn & Crutcher LLP NOW THEREFORE, IT IS HEREBY STIPULATED, pursuant to Civil L.R. 6-1(a), by and between Lead Plaintiff and Defendants, that the time in which Defendants must file and serve a response to the First Amended Complaint is extended until April 30, 2010. DATED: March 12, 2010 GIBSON, DUNN & CRUTCHER LLP By: /s/ Sally J. Berens Attorneys for Defendants CADENCE DESIGN SYSTEMS, INC., MICHAEL J. FISTER, KEVIN S. PALATNIK, WILLIAM PORTER and KEVIN BUSHBY DATED: March 12, 2010 COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP By: /s/ Shawn A. Williams Lead Counsel for Plaintiffs UNIT ED S ISTRIC ES D TC AT T ER N F D IS T IC T O R 2 STIPULATION TO ENLARGE TIME TO ANSWER FIRST AMENDED COMPLAINT CASE NO. C-08-4966 A C LI FO Judge S amuel C onti R NIA IT IS S O ORD ERED RT U O NO RT H

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