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

Filing 71

STIPULATION AND MODIFIED ORDER re 70 Order on Stipulation RE 67 MOTION to Dismiss the Second Amended Class Action Complaint for Violations of the Federal Securities Laws; Memorandum of Points and Authorities in Support Thereof. Res ponses due by 8/11/2014. Replies due by 8/25/2014. Motion Hearing set for 10/2/2014 10:00 AM in Courtroom 4, 17th Floor, San Francisco before Hon. Vince Chhabria. Signed by Judge Vince Chhabria on 7/25/2014. (knm, COURT STAFF) (Filed on 7/28/2014)

1 LIONEL Z. GLANCY (#134180)
MICHAEL M. GOLDBERG (#188669)
2 JOSHUA L. CROWELL (#295411)
ROBERT V. PRONGAY (#270796)
3 CASEY E. SADLER (#274241)
GLANCY BINKOW & GOLDBERG LLP
4 1925 Century Park East, Suite 2100
Los Angeles, California 90067
5 Telephone: [phone]
Facsimile: [phone]
6 Email:
[e-mail]
7 BETH A. KASWAN (pro hac vice motion pending)
DEBORAH CLARK-WEINTRAUB
8 DONALD A. BROGGI
AMANDA F. LAWRENCE
9 JOSEPH D. COHEN (#155601)
SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
10 The Chrysler Building
405 Lexington Avenue, 40th Floor
11 New York, New York 10174
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for Lead Plaintiff
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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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18 POLICE AND FIRE RETIREMENT
SYSTEM OF THE CITY OF DETROIT,
19 Individually and On Behalf of All Others
Similarly Situated,,
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Plaintiff,
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v.
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ROSEMARY A. CRANE, PATRICK D.
23 SPANGLER, and EPOCRATES, INC.,,
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Case No. 5:13-cv-00945-VC
STIPULATION AND [PROPOSED]
ORDER TO MODIFY DEADLINES FOR
DEFENDANTS’ MOTION TO DISMISS
THE SECOND AMENDED COMPLAINT
AS MODIFIED
Dep’t: 4, 17th Floor
Judge: Hon. Vince Chhabria

Defendants.

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287327.3

STIPULATION AND [PROPOSED] ORDER TO MODIFY DEADLINES FOR MOTION TO DISMISS
Case No. 5:13-cv-00945-VC

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Pursuant to Local Rule 6-2 and Your Honor’s Standing Order for Civil Cases, this Stipulation

2 is entered into by and among Lead Plaintiff Police and Fire Retirement System of the City of Detroit
3 (“Lead Plaintiff”) and Defendants Epocrates, Inc., Rosemary A. Crane, and Patrick D. Spangler
4 (“Defendants”), by and through their respective attorneys of record.
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WHEREAS, on June 25, 2014, Lead Plaintiff filed the Second Amended Class Action

6 Complaint for Violations of the Federal Securities Laws (ECF No. 66);
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WHEREAS, on July 14, 2014, Defendants filed their Motion to Dismiss the Second Amended

8 Class Action Complaint for Violations of the Federal Securities Laws (ECF No. 67) (the “Motion”),
9 with a noticed hearing date of September 18, 2014;
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WHEREAS, currently Lead Plaintiff’s opposition to the Motion is due on July 28, 2014, and

11 Defendants’ reply is due on August 4, 2014;
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WHEREAS, due to scheduling conflicts for Lead Plaintiff’s Counsel, the parties agreed to

13 modify the briefing schedule for the Motion and move the hearing date;
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WHEREAS, a new hearing date of October 2, 2014 has been reserved with the Court; and

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WHEREAS, this is the first request for a modification of the schedule for this Motion;

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THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the parties

17 hereto, that:
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1.

Plaintiffs’ opposition is due on August 11, 2014;

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2.

Defendants’ reply is due on August 25, 2014; and

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3.

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SO STIPULATED.

10:00 a.m.
The hearing on the Motion is scheduled for October 2, 2014 at 1:30 p.m.

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287327.3

STIPULATION AND [PROPOSED] ORDER TO MODIFY DEADLINES FOR MOTION TO DISMISS
Case No. 5:13-cv-00945-VC

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1 DATED: July 24, 2014

GLANCY BINKOW & GOLDBERG LLP

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By: /s Joshua L. Crowell
Lionel Z. Glancy
Michael M. Goldberg
Joshua L. Crowell
Robert V. Prongay
Casey E. Sadler
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
Beth A. Kaswan (pro hac vice motion pending)
Deborah Clark-Weintraub
Donald A. Broggi
Amanda F. Lawrence
Joseph D. Cohen
The Chrysler Building
405 Lexington Avenue. 40th Floor
New York, New York 10174
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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DAVID R. SCOTT
156 South Main Street, P.O. Box 192
Colchester, Connecticut 06415
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Lead Plaintiff

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287327.3

STIPULATION AND [PROPOSED] ORDER TO MODIFY DEADLINES FOR MOTION TO DISMISS
Case No. 5:13-cv-00945-VC

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1 DATED: July 24, 2014

GOODWIN PROCTER LLP

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By: /s Michael T. Jones
Michael T. Jones (SBN 290660)
135 Commonwealth Drive
Menlo Park, California 94025
Tel.: [phone]
Fax: [phone]
[e-mail]
Deborah S. Birnbach (pro hac vice)
Exchange Place
53 State Street
Boston, Massachusetts 02109
Tel.: [phone]
Fax: [phone]
[e-mail]
Teodora E. Manolova (SBN 233333)
601 S Figueroa St., 41st Floor
Los Angeles, California 90017
Tel: [phone]
Fax: [phone]
[e-mail]
Counsel for Defendants

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287327.3

STIPULATION AND [PROPOSED] ORDER TO MODIFY DEADLINES FOR MOTION TO DISMISS
Case No. 5:13-cv-00945-VC

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RT

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ER

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R NIA

NO

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Honorable Vince Chhabria
United States District Judge
habr ia
ince Ch
J u d ge V

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DERED

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IT IS S

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DATED: July ___, 2014

UNIT
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1 PURSUANT TO STIPULATION, IT IS SO ORDERED.

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D IS T IC T O
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287327.3

STIPULATION AND [PROPOSED] ORDER TO MODIFY DEADLINES FOR MOTION TO DISMISS
Case No. 5:13-cv-00945-VC

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PROOF OF SERVICE

2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
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At the time of service, I was over 18 years of age and not a party to this action. I am employed
in the County of Los Angeles, State of California. My business address is 1925 Century Park East,
4 Suite 2100, Los Angeles, CA 90067.
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On July 24, 2014, I served true copies of the following document(s) described as
STIPULATION AND [PROPOSED] ORDER TO MODIFY DEADLINES FOR
6 DEFENDANTS’ MOTION TO DISMISS THE SECOND AMENDED COMPLAINT on the
interested parties in this action as listed on the Court’s ECF Service List.
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BY CM/ECF NOTICE OF ELECTRONIC FILING: I electronically filed the document(s)
8 with the Clerk of the Court by using the CM/ECF system. Participants in the case who are registered
CM/ECF users will be served by the CM/ECF system. Participants in the case who are not registered
9 CM/ECF users will be served by mail or by other means permitted by the court rules.
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I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct and that I am employed in the office of a member of the bar of this Court
11 at whose direction the service was made.
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Executed on July 24, 2014, at Los Angeles, California.

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s/Joshua L. Crowell
Joshua L. Crowell

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287327.3

STIPULATION AND [PROPOSED] ORDER TO MODIFY DEADLINES FOR MOTION TO DISMISS
Case No. 5:13-cv-00945-VC