Kishtagari v. Geron Corporation et al

Filing 66

ORDER granting 65 STIPULATION TO EXTEND TIME FOR DEFENDANTS TO FILE THEIR REPLY IN SUPPORT OF MOTION TO DISMISS PLAINTIFFS CONSOLIDATED AMENDED CLASS ACTION COMPLAINT filed by Olivia K. Bloom, et al. Reset Deadlines as to 54 MOTION to Dismiss Consolidated Amended Class Action Complaint. Replies due by 2/25/2015. Motion Hearing set for 4/10/2015 10:00 AM in Courtroom 6, 17th Floor, San Francisco before Hon. Charles R. Breyer. Signed by Judge Charles R. Breyer on 2/11/2015. (beS, COURT STAFF) (Filed on 2/11/2015)

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COOLEY LLP
JOHN C. DWYER (136533) ([e-mail])
BRETT DE JARNETTE (292919) ([e-mail])
3175 Hanover Street
Palo Alto, CA 94304
Telephone:
[phone]
Facsimile:
[phone]
COOLEY LLP
RYAN E. BLAIR (246724) ([e-mail])
4401 Eastgate Mall
San Diego, CA 92121
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants
Geron Corporation, John A. Scarlett, Olivia K. Bloom, and
Stephen M. Kelsey

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[Additional counsel listed on signature page]
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Case No.: 14-cv-01224-CRB

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In re: GERON CORPORATION
SECURITIES LITIGATION

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STIPULATION AND ORDER TO EXTEND
TIME FOR DEFENDANTS TO FILE THEIR
REPLY IN SUPPORT OF MOTION TO
DISMISS PLAINTIFF’S CONSOLIDATED
AMENDED CLASS ACTION COMPLAINT

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CLASS ACTION

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Judge:
Courtroom:

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Hon. Charles R. Breyer
6, 17th Floor

This Document Relates To: All Cases

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COOLEY LLP
A TTORN E YS A T L A W

STIPULATION AND [PROPOSED] ORDER
14-CV-01224-CRB

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Pursuant to Civil Local Rules 6-2 and 7-12, lead plaintiff Vinod Patel (“Lead Plaintiff”)

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and defendants Geron Corporation, John A. Scarlett, and Olivia K. Bloom (collectively

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“Defendants,” and together with Lead Plaintiff, the “Parties”), hereby agree and stipulate to

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extend Defendants’ deadline to file their reply in support of their Motion to Dismiss Plaintiff’s

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Consolidated Amended Class Action Complaint (“Motion to Dismiss”) and to reschedule the

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Court’s current hearing date for the Motion to Dismiss, subject to the Court’s approval.

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WHEREAS, on July 21, 2014 the Court approved the parties’ stipulated briefing

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schedule, which called for Defendants’ reply in support of the Motion to Dismiss (“Reply”) to be

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filed on or before February 18, 2015 (Dkt. No. 44);

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WHEREAS, due to recent developments, counsel for Defendants will be out of the

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country or out of the state on unavoidable work-related matters through February 16, 2015, and is

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therefore requesting a short, one-week extension to file the Reply;

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WHEREAS, counsel for Defendants met and conferred with Lead Plaintiff’s counsel on

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February 5 and February 9, 2015, and Lead Plaintiff’s counsel has no objection to the short, one-

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week extension to file the Reply;

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WHEREAS, the hearing date for the Motion to Dismiss is currently scheduled for March
6, 2015;
WHEREAS, the Parties have reviewed the Court’s calendar, which now states that the
Court is no longer available on March 6, 2015;
WHEREAS, counsel for the Parties are available on April 10, 2015 for the hearing on the
Motion to Dismiss;
NOW, THEREFORE, IT HEREBY IS STIPULATED AND AGREED by the Parties
hereto, through their undersigned counsel, as follows:

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1.

Defendants shall have until February 25, 2015 to file and serve their Reply.

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2.

The hearing date for the Motion to Dismiss, currently scheduled for March 6,

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2015, shall be rescheduled to April 10, 2015, subject to the Court’s approval.
IT IS SO STIPULATED.

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COOLEY LLP
A TTORN E YS A T L A W

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STIPULATION AND [PROPOSED] ORDER
14-CV-01224-CRB

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Dated: February 9, 2015
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COOLEY LLP
JOHN C. DWYER
RYAN E. BLAIR
BRETT DE JARNETTE

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/s/ Ryan E. Blair
Ryan E. Blair (246724)

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Counsel for Defendants
Geron Corporation, John A. Scarlett, Olivia K.
Bloom, and Stephen M. Kelsey

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8 Dated: February 9, 2015
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FARUQI & FARUQI LLP
DAVID E. BOWER
RICHARD W. GONNELLO
MEGAN M. SULLIVAN
/s/ Richard W. Gonnello
Richard W. Gonnello (Pro Hac Vice)

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Counsel for Lead Plaintiff Vinod Patel

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ATTESTATION (CIVIL LOCAL RULE 5-1(i)(3))
In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing
of this document has been obtained from the signatories.
Dated: February 9, 2015

COOLEY LLP
JOHN C. DWYER (136533)
RYAN E. BLAIR (246724)

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/s/ Ryan E. Blair
Ryan E. Blair (246724)
Counsel for Defendants
Geron Corporation, John A. Scarlett, Olivia K.
Bloom, and Stephen M. Kelsey

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COOLEY LLP
A TTORN E YS A T L A W

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STIPULATION AND [PROPOSED] ORDER
14-CV-01224-CRB

PURSUANT TO STIPULATION, IT IS SO ORDERED

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S DISTRICT
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Dated: February 11, 2015

THE HONORABLE CHARLES BREYER
UNITED STATES DISTRICT COURT JUDGE

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A TTORN E YS A T L A W

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STIPULATION AND [PROPOSED] ORDER
14-CV-01224-CRB