Vitalone v. Logitech International SA et al

Filing 28

STIPULATION AND ORDER RE 27 FILING OF COMPLAINT AND RESPONSE THERETO. Signed by Judge Richard Seeborg on 12/20/11. (cl, COURT STAFF) (Filed on 12/20/2011)

*E-Filed 12/20/11*

1 ROBBINS GELLER RUDMAN
& DOWD LLP
2 DENNIS J. HERMAN (220163)
Post Montgomery Center
3 One Montgomery Street, Suite 1800
San Francisco, CA 94104
4 Telephone: [phone]
415/288-4534 (fax)
5 [e-mail]
6 Lead Counsel for Plaintiffs
7 [Additional Counsel on Signature Page]
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

10 CARL VITALONE, Individually and on
Behalf of All Others Similarly Situated,
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Plaintiff,
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vs.
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LOGITECH INTERNATIONAL SA, et al.,
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Defendants.
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672495_1

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No. 3:11-cv-03855-RS
CLASS ACTION
STIPULATION AND [PROPOSED] ORDER
REGARDING FILING OF COMPLAINT
AND RESPONSE THERETO

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Lead Plaintiff Sing Pui Leung (“Leung”) and Defendants Logitech International S.A., Gerald

2 P. Quindlen and Erik Bardman hereby jointly seek entry of the following proposed schedule, and as
3 grounds therefor state as follows:
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On October 24, 2011, the parties submitted a Stipulation and [Proposed] Consolidation Order

5 (Dkt. No. 22) (“Stipulation”) establishing deadlines for filing a consolidated complaint in this action,
6 briefing any motion directed at the pleadings, and addressing other matters pursuant to Civil
7 L.R. 23-1(b). At the October 27, 2011 hearing on Leung’s motion seeking appointment as the lead
8 plaintiff in this action, the Court indicated it had reviewed and would approve the Stipulation. The
9 Court has not yet entered the Stipulation.
10

Under the Stipulation, Lead Plaintiff’s consolidated complaint would be due to be filed on

11 December 27, 2011, which is 60 days after entry of the Court’s order appointing Leung as the lead
12 plaintiff for this action. See Stipulation, ¶11; Dkt. No. 26. Due to the departure of one of the
13 attorneys handling this matter on behalf of Lead Counsel, and other staffing disruptions caused by
14 the holidays, Lead Counsel, with the approval of the Lead Plaintiff, has sought Defendants’
15 agreement to a brief extension of the filing deadline, to which they have agreed. Accordingly, the
16 parties hereby submit a revised schedule which modifies ¶11 of the prior Stipulation to establish a
17 January 9, 2012 deadline for Lead Plaintiff to file a consolidated complaint.
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THEREFORE, it is hereby stipulated by the parties, subject to the approval of the Court, that

19 Lead Plaintiff shall file a consolidated complaint on or before January 9, 2012. The consolidated
20 complaint shall be the operative complaint and shall supersede all complaints filed in this action.
21 Defendants shall respond to the consolidated complaint within sixty (60) days after service. If
22 defendants file any motions directed at the consolidated complaint, the opposition and reply briefs
23 shall be filed within 60 days and 30 days, respectively, of that response.
24 DATED: December 20, 2011
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ROBBINS GELLER RUDMAN
& DOWD LLP
DENNIS J. HERMAN

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s/ Dennis J. Herman
DENNIS J. HERMAN

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672495_1

STIPULATION AND [PROPOSED] ORDER REGARDING FILING OF COMPLAINT AND
RESPONSE THERETO - 3:11-cv-03855-RS

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1
Post Montgomery Center
One Montgomery Street, Suite 1800
San Francisco, CA 94104
Telephone: [phone]
415/288-4534 (fax)

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ROBBINS GELLER RUDMAN
& DOWD LLP
SAMUEL H. RUDMAN
DAVID A. ROSENFELD
MARIO ALBA JR.
58 South Service Road, Suite 200
Melville, NY 11747
Telephone: [phone]
631/367-1173 (fax)

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Lead Counsel for Plaintiffs
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11 DATED: December 20, 2011
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WILSON SONSINI GOODRICH & ROSATI PC
IGNACIO E. SALCEDA
DIANE M. WALTERS
BENJAMIN M. CROSSON

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s/ Ignacio E. Salceda (w/ permission)
IGNACIO E. SALCEDA

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650 Page Mill Road
Palo Alto, CA 94304-1050
Telephone: [phone]
650/565-5100 (fax)

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Attorneys for Defendants Logitech International
S.A., Gerald P. Quindlen and Erik Bardman

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I, Dennis J. Herman, am the ECF User whose ID and password are being used to file this

21 STIPULATION AND [PROPOSED] ORDER REGARDING FILING OF COMPLAINT AND
22 RESPONSE THERETO. In compliance with General Order 45, X.B., I hereby attest that Ignacio E.
23 Salceda has concurred in this filing.
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s/ Dennis J. Herman
DENNIS J. HERMAN

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STIPULATION AND [PROPOSED] ORDER REGARDING FILING OF COMPLAINT AND
RESPONSE THERETO - 3:11-cv-03855-RS

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ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.

12/20/11
4 DATED: _________________________
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____________________________________
THE HONORABLE RICHARD SEEBORG
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER REGARDING FILING OF COMPLAINT AND
RESPONSE THERETO - 3:11-cv-03855-RS

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