Police and Fire Retirement System of the City of Detroit v. Crane et al

Filing 107

Order as Modified by Hon. Vince Chhabria granting 106 Stipulation to Reschedule Case Management Conference and Related Deadlines.(knm, COURT STAFF) (Filed on 6/29/2015)

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Deborah S. Birnbach (pro hac vice)
[e-mail]
GOODWIN PROCTER LLP
53 State Street
Boston, Massachusetts 02109
Tel:
617.570.1000
Fax:
617.523.1231
Michael T. Jones (SBN 290660)
[e-mail]
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025
Tel.:
650.752.3100
Fax.: [phone]

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Attorneys for Defendants
Epocrates, Inc., Rosemary A. Crane,
and Patrick D. Spangler

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[Additional counsel appear on signature page]

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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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POLICE AND FIRE RETIREMENT SYSTEM
OF THE CITY OF DETROIT, Individually and
On Behalf of All Others Similarly Situated,

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Plaintiffs,
v.
ROSEMARY A. CRANE, PATRICK D.
SPANGLER, and EPOCRATES, INC.,
Defendants.

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310150.1 EPOCRATES (Case

No. 3:13-CV-00945-VC)

Case No. 3:13-CV-00945-VC
CLASS ACTION
STIPULATION AND [PROPOSED]
ORDER TO RESCHEDULE CASE
MANAGEMENT CONFERENCE AND
RELATED DEADLINES AS MODIFIED
Dept:
Judge:

4, 17th Floor
Hon. Vince Chhabria

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Pursuant to Civil Local Rules 7-12 and 16-2, Defendants Rosemary A. Crane, Patrick D.

2 Spangler, and Epocrates, Inc. (“Defendants”) and Lead Plaintiff Police and Fire Retirement System
3 of the City of Detroit (“Lead Plaintiff”) (collectively “Parties”) hereby agree and stipulate that good
4 cause exists to request an order from the Court rescheduling the July 7, 2015 case management
5 conference to August 4, 2015, and rescheduling the related deadline for submission of a case
6 management statement from June 30, 2015 to July 28, 2015.
RECITALS

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WHEREAS, on March 13, 2015, the Court issued an Order denying Defendants’ Motion to

9 Dismiss the Third Amended Complaint, and scheduling a telephonic case management conference
10 for April 7, 2015;
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WHEREAS, based upon Defendants’ request due to scheduling conflicts, the Court

12 rescheduled the case management conference for April 14, 2015;
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WHEREAS, on April 8, 2015, in connection with the Parties’ scheduled mediation session

14 in New York City, New York before the Honorable Layn Phillips, the Court entered an Order
15 Granting the Parties’ Stipulation to reschedule the case management conference from April 14,
16 2015 to July 7, 2015, and to reset all related deadlines accordingly;
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WHEREAS, on June 23, 2015, the Parties conducted the scheduled mediation session in

18 New York City, New York before the Honorable Layn Phillips;
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WHEREAS, while the Parties were unable to resolve this action on June 23, 2015, the

20 mediation remains open and the Parties are continuing to explore a settlement of this action;
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WHEREAS, the Parties feel that their time over the next four weeks is best spent on

22 further exploring a settlement of this action;
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WHEREAS, as such, the Parties are requesting a modest four-week extension of the case

24 management conference currently scheduled for July 7, 2015, and a corresponding three-week
25 extension of the current June 30, 2015 deadline by which the Parties must submit a case
26 management statement;
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STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE AND
RELATED DEADLINES
(Case No. 3:13-CV-00945-VC)

WHEREAS, this is the third request for a modification of the schedule following the

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2 Court’s March 13, 2015 order;
WHEREAS, the Parties do not seek to reset these dates for the purpose of delay, and the

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4 proposed new date will not have an effect on any pre-trial and trial dates as the Court has yet to
5 schedule these dates;
THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the

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7 Parties through their undersigned counsel, subject to the Court’s entry and approval, that:
1.

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The July 7, 2015 case management conference is rescheduled to August 4, 2015,

9 and the corresponding deadline by which the Parties must submit a case management statement is
10 reset to July 28, 2015;
2.

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This Stipulation is entered into without prejudice to any party seeking any interim

12 relief.
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD

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Dated: June 26, 2015

GOODWIN PROCTER LLP

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By: /s/ Michael T. Jones
Michael T. Jones (# 290660)
135 Commonwealth Drive
Menlo Park, CA 94025
Tel.: [phone]
Fax.: [phone]
[e-mail]

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Deborah S. Birnbach (admitted pro hac vice)
Exchange Place
53 State Street
Boston, Massachusetts 02109
Tel.: [phone]
Fax.: [phone]
[e-mail]

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Counsel for Defendants
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STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE AND
RELATED DEADLINES
(Case No. 3:13-CV-00945-VC)

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Dated: June 26, 2015

GLANCY PRONGAY & MURRAY LLP

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By: /s/ Joshua L. Crowell

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Lionel Z. Glancy (# 134180)
Joshua L. Crowell (#295411)
Robert V. Prongay (#270796)
Casey E. Sadler (#274241)
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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SCOTT+SCOTT LLP
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Beth A. Kaswan (admitted pro hac vice)
Deborah Clark-Weintraub (admitted pro hac vice)
Amanda F. Lawrence (admitted pro hac vice)
The Chrysler Building
405 Lexington Avenue 40th Floor
New York, NY 10174
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Counsel for Lead Plaintiff

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STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE AND
RELATED DEADLINES
(Case No. 3:13-CV-00945-VC)

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No further extensions will be granted.
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: June _______, 2015

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United States District Judge
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HonorableMO Chhabria
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STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE AND
RELATED DEADLINES
(Case No. 3:13-CV-00945-VC)