Smith v. TeleNav, Inc. et al

Filing 6

STIPULATION AND ORDER The Case Management Conference set for 12/17/2010 is continued to 6/10/2011 10:00 AM in Courtroom 1, 17th Floor, San Francisco. Signed by Judge Samuel Conti on 10/5/10. (tdm, COURT STAFF) (Filed on 10/5/2010)

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BORIS FELDMAN, State Bar No. 128838 [e-mail] DOUGLAS J. CLARK, State Bar No. 171499 [e-mail] CAZ HASHEMI, State Bar No. 210239 [e-mail] BENJAMIN M. CROSSON, State Bar No. 247560 [e-mail] MOLLY A. ARICO, State Bar No. 260472 [e-mail] WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, C A 94304-1050 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants TeleNav, Inc., H.P. Jin, Douglas S. Miller, Shawn Carolan, Samuel Chen, Hon Jane Chiu, Soo Boon Koh, and Joseph M. Zaelit UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION DAVID SMITH, Individually and on Behalf of All Other Similarly Situated, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO.: 3:10-cv-3942-SC REVISED STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND AND CONTINUING CASE MANAGEMENT CONFERENCE

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REVISED STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND AND CONTINUING CASE MANAGEMENT CONFERENCE, C-10-3942-SC

TELENAV, INC., H.P. JIN, DOUGLAS S. MILLER, SHAWN CAROLAN, SAMUEL CHEN, HON JANE CHIU, SOO BOON KOH, JOSEPH M. ZAELIT, J.P. MORGAN SECURITIES INC. and DEUTSCHE BANK SECURITIES INC., Defendants.

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WHEREAS, Plaintiff David Smith filed a Complaint against Defendants TeleNav, Inc., H.P. Jin, Douglas S. Miller, Shawn Carolan, Samuel Chen, Hon Jane Chiu, Soo Boon Koh, Joseph M. Zaelit, J.P. Morgan Securities Inc., and Deutsche Bank Securities Inc. on September 2, 2010 (the "Action"); WHEREAS, a number of the Defendants were served with the summons and complaint; WHEREAS, the undersigned parties anticipate that additional complaints may be filed, and a Lead Plaintiff and Lead Counsel will need to be appointed; WHEREAS, the undersigned parties anticipate that, following the appointment of Lead Plaintiff, an amended complaint will be filed; WHEREAS, the case management conference is currently scheduled before this Court on December 17, 2010 at 10:00 a.m.; NOW, THEREFORE, in the interest of judicial economy and good cause showing, the parties, by and through their undersigned counsel of record, hereby agree and stipulate, and the Court hereby orders, as follows: 1. 2. Defendants need not respond to the complaint filed September 2, 2010; After the appointment of a Lead Plaintiff and Lead Counsel, Defendants and Lead

Plaintiff shall meet and confer to determine a schedule for the filing of an amended complaint, and Defendants' response thereto. The parties will file a stipulated schedule for approval by the Court; and 3. The case management conference currently scheduled for December 17, 2010 at

10:00 a.m. shall be continued until June 10, 2011 at 10:00 a.m. The parties shall file one joint case management statement seven (7) days prior to June 10, 2011. The Parties respectfully request that the Court enter an Order approving this Stipulation.

REVISED STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND AND CONTINUING CASE MANAGEMENT CONFERENCE, C-10-3942-SC

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Respectfully submitted, WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, C A 94304 Telephone: [phone] Facsimile: [phone]

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REVISED STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND AND CONTINUING CASE MANAGEMENT CONFERENCE, C-10-3942-SC

/s/ Caz Hashemi Caz Hashemi

Attorneys for Defendants TeleNav, Inc., H.P. Jin, Douglas S. Miller, Shawn Carolan, Samuel Chen, Hon Jane Chiu, Soo Boon Koh, and Joseph M. Zaelit

Dated: October 4, 2010

ROBBINS GELLER RUDMAN & DOWD LLP Post Montgomery Center One Montgomery Street, Suite 1800 San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone]

/s/ Shawn A. Williams Shawn A. Williams

Attorneys for Plaintiff David Smith

ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Dated:

October 5, 2010

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ATTESTATION PURSUANT TO GENERAL ORDER 45 I, Caz Hashemi, attest that concurrence in the filing of this document has been obtained from the signatory, Shawn A. Williams. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 4th day of October, 2010 at San Francisco, California.

By:

/s/ Caz Hashemi Caz Hashemi

Attorneys for Defendants TeleNav, Inc., H.P. Jin, Douglas S. Miller, Shawn C arolan, Samuel Chen, Hon Jane Chiu, Soo Boon Koh, and Joseph M. Zaelit

REVISED STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND AND CONTINUING CASE MANAGEMENT CONFERENCE, C-10-3942-SC

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