Johnson et al v. OCZ Technology Group, Inc. et al

Filing 45

STIPULATION AND ORDER REGARDING EXTENSION OF TIME TO RESPOND TO CONSOLIDATED AMENDED CLASS ACTION COMPLAINT AND CONTINUING CASE MANAGEMENT CONFERENCE. Case Management Conference set for 12/12/2013 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 9/25/13. (cl, COURT STAFF) (Filed on 9/25/2013)

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BORIS FELDMAN, State Bar No. 128838
Email: [e-mail]
CAZ HASHEMI, State Bar No. 210239
Email: [e-mail]
DIANE M. WALTERS, State Bar No. 148136
Email: [e-mail]
NAIRA DER KIUREGHIAN, State Bar No. 282391
Email: [e-mail]
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
650 Page Mill Road
Palo Alto, CA 94304-1050
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
OCZ Technology Group, Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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IN RE OCZ TECHNOLOGY GROUP, INC.
SECURITIES LITIGATION

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STIPULATION AND [PROPOSED]
ORDER RE EXTENSION OF TIME
CASE NO. 12-CV-05265-RS

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CASE NO.: 12-CV-05265-RS
STIPULATION AND [PROPOSED]
ORDER REGARDING EXTENSION
OF TIME TO RESPOND TO
CONSOLIDATED AMENDED CLASS
ACTION COMPLAINT AND
CONTINUANCE OF CASE
MANAGEMENT CONFERENCE
DATE: N/A
TIME:
N/A
JUDGE: Hon. Richard Seeborg

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WHEREAS, on March 5, 2013, plaintiffs in the above-captioned action filed a
Consolidated Amended Class Action Complaint (the “Consolidated Amended Complaint”);

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WHEREAS, in light of the parties’ agreement to participate in private mediation

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proceedings, the parties previously stipulated to extend Defendants’ deadline to respond to the

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Consolidated Amended Complaint to October 4, 2013, and the Court granted the requested

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extension (Dkt. No. 43);

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WHEREAS, a Case Management Conference in the above-captioned action currently is
scheduled for October 3, 2013;
WHEREAS, on September 13, 2013, the parties participated in a private mediation before
the Honorable Edward A. Infante (ret.);

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WHEREAS, the parties currently are engaging in continuing settlement discussions;

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WHEREAS, in light of the foregoing, the parties have agreed, subject to Court approval, to

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continue the date for Defendants’ deadline to respond to the Consolidated Amended Complaint by

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thirty (30) days, or until November 4, 2013;

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WHEREAS, the parties further request that the October 3, 2013 Case Management
Conference be continued for sixty (60) days, or until such date as is convenient for the Court;
WHEREAS, the requested extensions are not for the purpose of delay and will not
prejudice any party;
THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the
undersigned, subject to Court approval, as follows:
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Defendants shall have until November 4, 2013 to respond to the Consolidated

Amended Complaint.
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The October 3, 2013 Case Management Conference is vacated and shall be

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continued until December 12, 2013, and the related Case Management Conference and ADR

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deadlines are continued in accordance with the December 12, 2013 CMC date.

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STIPULATION AND [PROPOSED]
ORDER RE EXTENSION OF TIME
CASE NO. 12-CV-05265-RS

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Dated: September 25, 2013

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

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By: /s/

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Diane M. Walters
Diane M. Walters
[e-mail]

Attorneys for Defendant
OCZ Technology Group, Inc.

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Dated: September 25, 2013

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HOGAN LOVELLS US LLP
525 University Avenue 4th Floor
Palo Alto, CA 94301
Telephone: [phone]
Facsimile: [phone]

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By: /s/
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Norman J. Blears
Norman J. Blears
[e-mail]

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Attorneys for Defendant
Arthur F. Knapp, Jr.

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Dated: September 25, 2013

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IRELL & MANELLA LLP
1800 Avenue of the Stars, Suite 900
Los Angeles, CA 90067
Telephone: [phone]
Facsimile: [phone]

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By: /s/
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Daniel P. Lefler
Daniel P. Lefler
[e-mail]

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Attorneys for Defendant
Ryan M. Petersen

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STIPULATION AND [PROPOSED]
ORDER RE EXTENSION OF TIME
CASE NO. 12-CV-05265-RS

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Dated: September 25, 2013

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LEVI & KORSINSKY LLP
1101 30th Street NW, Suite 115
Washington, DC 20007
Telephone: [phone]
Facsimile: [phone]

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By: /s/

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Nicholas I. Porritt
Nicholas I. Porritt
Email: [e-mail]

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PUNZALAN LAW, P.C.
600 Allerton Street, Suite 201
Redwood City, CA 94063
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Lead Plaintiff The OCZ Investor
Group

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STIPULATION AND [PROPOSED]
ORDER RE EXTENSION OF TIME
CASE NO. 12-CV-05265-RS

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I, Diane M. Walters, am the ECF user whose ID and password are being used to file this

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STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION OF TIME TO

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RESPOND TO CONSOLIDATED AMENDED CLASS ACTION COMPLAINT AND

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CONTINUANCE OF CASE MANAGEMENT CONFERENCE. In compliance with General

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Order 45, X.B., I hereby attest that Norman J. Blears, Daniel P. Lefler, and Nicholas Porritt have

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concurred in this filing.

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Dated: September 25, 2013

WILSON SONSINI GOODRICH & ROSATI
Professional Corporation

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By: /s/

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STIPULATION AND [PROPOSED]
ORDER RE EXTENSION OF TIME
CASE NO. 12-CV-05265-RS

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Diane M. Walters
Diane M. Walters
[e-mail]

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ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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THE HONORABLE RICHARD SEEBORG
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED]
ORDER RE EXTENSION OF TIME
CASE NO. 12-CV-05265-RS

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