Bodri v. GoPro, Inc. et al

Filing 111

STIPULATION AND ORDER Signed by Judge Jon S. Tigar on 5/19/2017 granting 110 Stipulation and [Proposed] Order to Extend the Deadline for Plaintiff to File an Amended Complaint. (tnS) (Filed on 5/19/2017)

1 ROBBINS GELLER RUDMAN
& DOWD LLP
2 SHAWN A. WILLIAMS (213113)
MATTHEW S. MELAMED (260272)
3 NADIM G. HEGAZI (264841)
Post Montgomery Center
4 One Montgomery Street, Suite 1800
San Francisco, CA 94104
5 Telephone: [phone]
415/288-4534 (fax)
6 [e-mail]
[e-mail]
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8 Lead Counsel for Plaintiff
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

12 JOSEPH BODRI, Individually and on Behalf
of All Others Similarly Situated,
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Plaintiff,
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vs.
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GOPRO, INC., et al.,
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Defendants.
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Lead Case No. 3:16-cv-00232-JST
(CONSOLIDATED)
CLASS ACTION
STIPULATION AND [PROPOSED] ORDER
TO EXTEND THE DEADLINE FOR
PLAINTIFF TO FILE AN AMENDED
COMPLAINT AND SETTING A BRIEFING
SCHEDULE

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Pursuant to Civil Local Rules 6-2 and 7-12, the parties – Lead Plaintiff Camia Investment

2 LLC (“Plaintiff”) and Defendants GoPro, Inc., Nicholas D. Woodman, Jack R. Lazar, and Anthony
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J. Bates (“Defendants”) – by and through their undersigned counsel of record, submit the following
stipulation and proposed order:
WHEREAS, on March 17, 2016, the Court previously granted the parties’ stipulated request
to extend the time for Defendants to respond to the initial complaints and to continue the case

8 management conferences in this and related actions (Dkt. No. 48);
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WHEREAS, on July 28, 2016, Plaintiff filed the Amended Consolidated Complaint for

10 Violations of the Federal Securities Laws (the “Complaint”) (Dkt. No. 90);
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WHEREAS, on September 26, 2016, Defendants moved to dismiss the Complaint (Dkt. No.
94); on November 16, 2016, Plaintiff filed its opposition to Defendants’ motion (Dkt. No. 98); and
on December 22, 2016, Defendants filed their reply in support of their motion (Dkt. No. 100);
WHEREAS, on January 19, 2017, the Court heard argument on Defendants’ motion to

16 dismiss the Complaint and took the motion under submission (Dkt. No. 104);
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WHEREAS, on May 1, 2017, the Court issued an Order granting Defendants’ motion to

18 dismiss the Complaint and providing Plaintiff 21 days, until May 22, 2017, to file an amended
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complaint (Dkt. No. 109);
WHEREAS, due to the need for additional time to address the reasons given by the Court for
dismissing the Complaint and to scheduling conflicts in other cases, Plaintiff requested additional

23 time to file an amended complaint;
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WHEREAS, the parties have met and conferred and have agreed, subject to Court approval,

25 that Plaintiff shall have until June 14, 2017 to file an amended complaint; and
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WHEREAS, the parties have also conferred regarding a briefing schedule in anticipation of
Defendants’ motion to dismiss the amended complaint, and have agreed, subject to Court approval,
STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR PLAINTIFF TO
FILE AN AMENDED COMPLAINT AND SETTING A BRIEFING SCHEDULE - 3:16-cv-00232-JST

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1 that Defendants shall have until July 18, 2017 to file such a motion, that Plaintiff shall have until
2 August 17, 2017 to file an opposition, and that Defendants shall have until August 31, 2017 to file a
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reply;
NOW, THEREFORE, the parties agree and stipulate that:
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Plaintiff shall have until June 14, 2017 to file an amended complaint; and

2.

In the event Plaintiff files an amended complaint and Defendants determine they will

move to dismiss the amended complaint:
(a)

Defendants shall have until July 18, 2017 to file the motion;

(b)

Plaintiff shall have until August 17, 2017 to file an opposition; and

(c)

Defendants shall have until August 31, 2017 to file a reply.

DATED: May 17, 2017

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ROBBINS GELLER RUDMAN
& DOWD LLP
SHAWN A. WILLIAMS
MATTHEW S. MELAMED
NADIM G. HEGAZI

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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Lead Counsel for Plaintiff

21 DATED: May 17, 2017

FENWICK & WEST LLP
CATHERINE KEVANE

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s/ Catherine Kevane
CATHERINE KEVANE
555 California Street, 12th Floor
San Francisco, CA 94104
Telephone: [phone]
415/693-2222 (fax)
Attorneys for Defendants GoPro, Inc., Nicholas
D. Woodman Jack R. Lazar and Anthony J. Bates
STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR PLAINTIFF TO
FILE AN AMENDED COMPLAINT AND SETTING A BRIEFING SCHEDULE - 3:16-cv-00232-JST

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I, Matthew S. Melamed, am the ECF User whose ID and password are being used to file this
Stipulation and [Proposed] Order to Extend the Deadline for Plaintiff to File an Amended Complaint
and Setting a Briefing Schedule. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that
Catherine Kevane has concurred in this filing.
s/ Matthew S. Melamed
MATTHEW S. MELAMED

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ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: May 19, 2017

____________________________________
THE HONORABLE JON S. TIGAR
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR PLAINTIFF TO
FILE AN AMENDED COMPLAINT AND SETTING A BRIEFING SCHEDULE - 3:16-cv-00232-JST

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CERTIFICATE OF SERVICE
I hereby certify that on May 17, 2017, I authorized the electronic filing of the foregoing with

3 the Clerk of the Court using the CM/ECF system which will send notification of such filing to the
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e-mail addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I
caused to be mailed the foregoing document or paper via the United States Postal Service to the nonCM/ECF participants indicated on the attached Manual Notice List.
I certify under penalty of perjury under the laws of the United States of America that the

9 foregoing is true and correct. Executed on May 17, 2017.
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s/ Matthew S. Melamed
MATTHEW S. MELAMED

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ROBBINS GELLER RUDMAN
& DOWD LLP
655 West Broadway, Suite 1900
San Diego, CA 92101-8498
Telephone: [phone]
619/231-7423 (fax)

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E-mail:[e-mail]

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STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR PLAINTIFF TO
FILE AN AMENDED COMPLAINT AND SETTING A BRIEFING SCHEDULE - 3:16-cv-00232-JST

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