Newett v. Leapfrog Enterprises, Inc. et al

Filing 144

STIPULATION AND ORDER TO RESET CMC re 142 filed by John Barbour, Raymond L. Arthur, Leapfrog Enterprises, Inc. Case Management Statement due by 9/21/2017. Further Case Management Conference set for 9/28/2017 10:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 9/5/17. (bpfS, COURT STAFF) (Filed on 9/5/2017)

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JORDAN ETH (CA SBN 121617)
[e-mail]
MARK R.S. FOSTER (CA SBN 223682)
[e-mail]
RYAN M. KEATS (CA SBN 296463)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
Attorneys for Defendants
LEAPFROG ENTERPRISES, INC., JOHN BARBOUR, and
RAYMOND L. ARTHUR

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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 LEAPFROG ENTERPRISES, INC.
SECURITIES LITIGATION

Case No.

3:15-CV-00347-EMC

CLASS ACTION

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This Document Relates To:
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ALL ACTIONS
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STIPULATION AND [PROPOSED] SCHEDULING ORDER
Case No. 3:15-CV-00347-EMC
sf-3819686

STIPULATION AND
[PROPOSED] SCHEDULING
ORDER

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Pursuant to Civil Local Rule 7-12, the parties – lead plaintiff KBC Asset Management

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NV (“Lead Plaintiff”) and defendants LeapFrog Enterprises, Inc., John Barbour, and

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Raymond L. Arthur (“Defendants”) – by and through their undersigned counsel of record, submit

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the following stipulation and proposed order:

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WHEREAS, on April 6, 2017, the Court directed the parties to complete private

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mediation and file an updated joint case management statement by July 6, 2017, and scheduled a

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case management conference for July 13, 2017 at 1:30 p.m. (Dkt. No. 123);

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WHEREAS, on multiple occasions the Court has granted the parties’ stipulated request to
continue the scheduled Initial Case Management Conference so that it was held at the same time
as hearings on Defendants’ motions to dismiss (Dkt. Nos. 49, 69, 96, 99, 108);
WHEREAS, on May 31, 2017, the Court granted the parties’ stipulated request to extend

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the deadline to conduct private mediation and to file an updated joint case management statement

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to September 7, 2017, in light of the mediator’s schedule, and to continue the July 13, 2017 case

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management conference to September 14, 2017;

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WHEREAS, the parties conducted private mediation on August 30, 2017, but were
unable to reach a negotiated resolution of the action;
WHEREAS, lead trial counsel for Defendants plans to appear on behalf of Defendants at
the next case management conference, but will be out of the country on September 14, 2017;
WHEREAS, the parties have conferred and agreed, subject to Court approval, that:

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(i) the deadline to file an updated joint case management statement should be extended to

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September 21, 2017; and (ii) the case management conference scheduled for September 14, 2017

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should be continued to September 28, 2017 at 10:30 a.m.

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NOW, THEREFORE, the parties hereby agree and stipulate, subject to Court approval, as

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follows:

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1. The deadline for the parties to file an updated joint case management statement is

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extended to September 21, 2017;
2. The case management conference scheduled for September 14, 2017 is continued to
September 28, 2017 at 10:30 a.m.
STIPULATION AND [PROPOSED] SCHEDULING ORDER
Case No. 3:15-CV-00347-EMC
sf-3819686

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DATED: July 6, 2017

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ROBBINS GELLER RUDMAN
& DOWD LLP
SHAWN A. WILLIAMS
WILLOW E. RADCLIFFE
MATTHEW S. MELAMED

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/s/ Matthew S. Melamed
MATTHEW S. MELAMED

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Post Montgomery Center
One Montgomery Street, Suite 1800
San Francisco, CA 94104
Telephone: [phone]
415/288-4534 (fax)

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MOTLEY RICE LLC
JAMES M. HUGHES
WILLIAM S. NORTON
CHRISTOPHER F. MORIARTY
28 Bridgeside Blvd.
Mount Pleasant, SC 29464
Telephone: [phone]
843/216-9450 (fax)

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Co-Lead Counsel for Plaintiffs

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DATED: July 6, 2017

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MORRISON & FOERSTER LLP
JORDAN ETH
MARK R.S. FOSTER
RYAN M. KEATS

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/s/ Ryan M. Keats
RYAN M. KEATS

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425 Market Street
San Francisco, CA 94105-2482
Telephone: [phone]
415/268-7522 (fax)

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Counsel for Defendants

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STIPULATION AND [PROPOSED] SCHEDULING ORDER
Case No. 3:15-CV-00347-EMC
sf-3819686

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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HON. EDWARD M. CHENDERED
UNITED STATESS SO OR JUDGE
T I DISTRICT

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Judge E

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9/5/17

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DATED:

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STIPULATION AND [PROPOSED] SCHEDULING ORDER
Case No. 3:15-CV-00347-EMC
sf-3819686

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ATTESTATION

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I, Ryan M. Keats, am the ECF User whose ID and password are being used to file this

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STIPULATION AND [PROPOSED] SCHEDULING ORDER. In compliance with Civil

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L.R. 5-1, I hereby attest that Matthew S. Melamed concurred in this filing.

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/s/ Ryan M. Keats
RYAN M. KEATS

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STIPULATION AND [PROPOSED] SCHEDULING ORDER
Case No. 3:15-CV-00347-EMC
sf-3819686

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