Kishtagari v. Geron Corporation et al

Filing 92

ORDER, granted as modified 91 STIPULATION WITH PROPOSED ORDER Removing from Calendar the Initial Case Management Conference filed by Olivia K. Bloom, Geron Corporation, Stephen Kelsey, John A. Scarlett. Case Management Conference reset for 11/13/2015 08:30 AM in Courtroom 6, 17th Floor, San Francisco, Supplemental Case Management Statement due by 11/6/2015. Signed by Judge Charles R. Breyer on 10/6/2015. (beS, COURT STAFF) (Filed on 10/7/2015)

1
2
3
4
5
6
7

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]

8
9

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

10
[Additional counsel listed on signature page]
11
12

UNITED STATES DISTRICT COURT

13

NORTHERN DISTRICT OF CALIFORNIA

14
Case No.: 14-cv-01224-CRB

15
16

In re: GERON CORPORATION
SECURITIES LITIGATION

CLASS ACTION
STIPULATION AND ORDER
REMOVING FROM CALENDAR
THE INITIAL CASE MANAGEMENT
CONFERENCE

17
18
19

Initial CMC Date:
Time:
Judge:
Courtroom:

20
21

October 23, 2015
8:30 am
Hon. Charles R. Breyer
6, 17th Floor

This Document Relates To:
22
23
24
25
26
27
28
COOLEY LLP
ATTO RNEY S AT LAW
PALO AL TO

STIPULATION AND [PROPOSED] ORDER
REMOVING FROM CALENDAR THE INITIAL CMC
14-CV-01224-CRB

1

Lead Plaintiff Vinod Patel (“Lead Plaintiff”) and Defendants Geron Corporation, John A.

2

Scarlett, Olivia K. Bloom, and Stephen M. Kelsey (collectively “Defendants” and together with

3

Lead Plaintiff, the “Parties”), by and through their undersigned counsel, hereby stipulate as

4

follows:

5

WHEREAS, on April 23, 2015 the Court granted the Stipulation and Order to Extend the

6

Time Within Which to Answer the Consolidated Amended Class Action Complaint and to Set the

7

Initial Case Management Conference (ECF No. 79) and thereby ordered that the Initial Case

8

Management Conference shall be held 60 days after Defendants file their answer to the

9

Consolidated Amended Class Action Complaint (“CAC”);

10

WHEREAS, on May 22, 2015, Defendants filed their answer to the CAC;

11

WHEREAS, the Court initially scheduled the Initial Case Management Conference to take

12

place on July 24, 2015;

13
14

WHEREAS, on June 30, 2015, the Court entered an order continuing the Initial Case
Management Conference to October 23, 2015 at 8:30 a.m.;

15

WHEREAS, the Parties have agreed to participate in a private mediation with Judge Layn

16

Phillips (Ret.), which initially had been scheduled for October 6, 2015, which was the earliest date

17

available;

18

WHEREAS, the Parties have been informed by Judge Phillips that he now has a conflict

19

with the October 6, 2015 mediation date, and the mediation has now been rescheduled for

20

November 2, 2015, which was the earliest date available; and

21

WHEREAS, the Parties have agreed to take the Initial Case Management Conference off

22

calendar during the pendency of mediation discussions, and will reset the conference if it becomes

23

necessary to do so.

24

///

25

///

26

///

27

///

28

///

COOLEY LLP
ATTO RNEY S AT LAW
PALO AL TO

1.

STIPULATION AND [PROPOSED] ORDER
REMOVING FROM CALENDAR THE INITIAL CMC
14-CV-01224-CRB

1

WHEREFORE, IT IS HEREBY STIPULATED AND AGREED that,

2

1.

3

Court’s calendar.

4

Dated: October 2, 2015

The October 23, 2015 Initial Case Management Conference is removed from the

5
6

COOLEY LLP
JOHN C. DWYER (136533)
RYAN E. BLAIR (246724)
BRETT DE JARNETTE (292919)

7
/s/ Ryan E. Blair
Ryan E. Blair (246724)

8
9

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

10
11
12
13

Dated: October 2, 2015

FARUQI & FARUQI, LLP
RICHARD W. GONNELLO (Admitted Pro Hac Vice)
MEGAN M. SULLIVAN (Admitted Pro Hac Vice)
KATHERINE M. LENAHAN (Admitted Pro Hac Vice)

14
15
16
17
18
19
20
21

/s/ Richard W. Gonnello
Richard W. Gonnello
369 Lexington Avenue, 10th Floor
New York, NY 10017
Telephone: [phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
[e-mail]

24

DAVID E. BOWER (119546)
10866 Wilshire Boulevard, Suite 1470
Los Angeles, CA 90024
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]

25

Counsel for Lead Plaintiff

22
23

26
27
28
COOLEY LLP
ATTO RNEY S AT LAW
PALO AL TO

2.

STIPULATION AND [PROPOSED] ORDER
REMOVING FROM CALENDAR THE INITIAL CMC
14-CV-01224-CRB

1
2
3

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 signatory.

4
5

Dated: October 2, 2015

COOLEY LLP

6
7

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

8

Counsel for Lead Plaintiff

9
10

ORDER

11

Pursuant to the foregoing stipulation, and good cause appearing, IT IS SO ORDERED.

12

The Initial Case Management Conference currently reset for October 23, 2015 at 8:30 a.m. has

13

been continued to November 13, 2015 at 8:30 a.m., supplemental case management statement

14

due November 6, 2015.

15

Dated: October 6, 2015

16
Honorable Charles R. Breyer
United States District Judge

17
18
19
20

122149604 v1

21
22
23
24
25
26
27
28
COOLEY LLP
ATTO RNEY S AT LAW
PALO AL TO

3.

STIPULATION AND [PROPOSED] ORDER
REMOVING FROM CALENDAR THE INITIAL CMC
14-CV-01224-CRB