Bodri v. GoPro, Inc. et al

Filing 88

STIPULATION AND ORDER re 87 STIPULATION WITH PROPOSED ORDER re 85 Order on Administrative Motion per Civil Local Rule 7-11 filed by Majesty Palms, LLP. Signed by Judge Jon S. Tigar on July 19, 2016. (wsn, COURT STAFF) (Filed on 7/19/2016)

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1 2 3 4 5 6 7 Patrice L. Bishop (182256) pbishop@ssbla.com STULL, STULL & BRODY 9430 W. Olympic Blvd., Suite 400 Beverly Hills, CA 90212 Tel: 310-209-2468 Fax: 310-209-2087 Counsel for Plaintiff Majesty Palms, LLLP [Additional Counsel on Signature Page] 8 UNITED STATES DISTRICT COURT 9 FOR THE NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 12 13 14 15 16 17 18 19 20 JOSEPH BODRI, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, GOPRO, INC., NICHOLAS WOODMAN, and JACK LAZAR, Defendants. 21 22 23 24 25 26 27 28 STIPULATION AND [PROPOSED] ORDER Case No. 3:16-cv-00232-JST ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 3:16-cv-00232-JST CLASS ACTION STIPULATION AND [PROPOSED] ORDER CONCERNING BRIEFING SCHEDULE FOR MOTIONS TO DISMISS JUDGE: CRTRM: Hon. Jon S. Tigar 9, 19th Floor 1 Pursuant to Civil Local Rules 3-12, 7-11 and 7-12, the Parties in each of the above-entitled 2 actions, by and through their counsel, hereby stipulate to the following: 4 Investment”) pursuant to the Private Securities Litigation Reform Act of 1995 (“PSLRA”) as lead 6 between July 21, 2015, and January 13, 2016 (Dkt. No. 76); 3 5 7 WHEREAS, on April 28, 2016, the Court appointed Camia Investment LLC (“Camia plaintiff in this action to represent a putative class of investors who purchased GoPro securities WHEREAS, on April 28, 2016, the Court appointed Majesty Palms, LLLP (“Majesty 8 Palms”) pursuant to the PSLRA as lead plaintiff in this action to represent a putative class of 10 WHEREAS, Camia Investment’s and Majesty Palms’ amended pleadings were due to be 9 investors who purchased GoPro securities between November 26, 2014, and July 20, 2015 (id.); 11 filed on June 21, 2016, Defendants’ motions to dismiss were due on August 22, 2016, responses in 13 motions to dismiss were due on November 21, 2016, and a hearing on the motions to dismiss was 12 14 15 opposition to the motions to dismiss were due on October 21, 2016, replies in support of the scheduled for December 22, 2016, at 2:00 p.m.; WHEREAS, on June 21, 2016, Majesty Palms filed an administrative motion seeking an 16 extension of 30 days to file an amended complaint (Dkt. No. 80); 18 Violations of the Federal Securities Laws (Dkt. No. 81); 20 Palms’ administrative motion and requested a single briefing schedule and hearing date for its 22 No. 84); 17 19 21 23 WHEREAS, on June 21, 2016, Camia Investment filed a Consolidated Complaint for WHEREAS, on June 27, 2016, Defendants filed a statement of non-opposition to Majesty anticipated motions to dismiss both the Camia Investment and Majesty Palms complaints (Dkt. WHEREAS, on June 28, 2016, the Court granted Majesty Palms’ administrative motion 24 for a 30-day extension of the due date to file its amended complaint, resulting in the complaint 26 WHEREAS, on June 28, 2016, the Court also ordered the parties to meet and confer 25 27 28 being due July 28, 2016 (Dkt. No. 85); regarding a single briefing schedule and hearing date for Defendants’ anticipated motions to dismiss (id.); STIPULATION AND [PROPOSED] ORDER Case No. 3:16-cv-00232-JST -1- 1 WHEREAS, the Parties have met and conferred and agreed on the following schedule in 2 light of the Court’s order and in consideration of fairness to all parties; 4 that: 6 Complaint for Violations of the Federal Securities Laws without prejudice as to further 8 Investment’s complaint, except that Defendants reserve their right to object to such further 3 5 7 9 10 IT IS HEREBY STIPULATED, by and between the undersigned counsel for the Parties, 1. Camia Investment shall have until July 28, 2016, to amend its Consolidated amendment in the event that the Court grants Defendants’ anticipated motion to dismiss Camia amendment on the ground that it is futile; 2. Defendants shall have until September 26, 2016, to respond to Camia Investment’s 3. If Defendants’ respond by moving to dismiss Camia Investment’s and Majesty 11 and Majesty Palms’ complaints; and 13 Palms’ complaints: 12 14 o Plaintiffs shall have until November 16, 2016, to file responses in o Defendants shall have until December 22, 2016, to file replies in support of o The Court shall hold hearings on the motions to dismiss at its earliest 15 opposition to the motions to dismiss; 17 the motions to dismiss; and 19 convenience after briefing is complete. 16 18 20 21 22 23 Dated: July 18, 2016 24 25 26 27 28 STIPULATION AND [PROPOSED] ORDER Case No. 3:16-cv-00232-JST ROBBINS GELLER RUDMAN & DOWD LLP By: /s/ Shawn A. Williams_______ Shawn A. Williams Post Montgomery Center One Montgomery Street Suite 1800 San Francisco, CA 94104 Tel: (415) 288-4545 Fax: (415) 288-4534 Email: shawnw@rgrdlaw.com 1 Michael I. Fistel , Jr. Johnson & Weaver, LLP 40 Powder Springs Street Marietta, GA 30064 Tel: (770) 200-3104 Fax: (770) 200-3101 Email: michaelf@johnsonandweaver.com 2 3 4 5 Attorneys for Camia Investment LLC 6 7 8 9 Dated: July 18, 2016 10 11 12 14 15 16 18 19 Attorneys for Plaintiff Majesty Palms, LLLP Dated: July 18, 2016 20 21 22 23 25 27 28 FENWICK & WEST LLP By: /s/Catherine D. Kevane _______ Catherine D. Kevane 555 California Street, 12th Floor San Francisco, California 94104 Tel: (415) 875-2300 Fax: (415) 281-1350 Email: ckevane@fenwick.com Attorneys for Defendants GoPro, Inc., Nicholas Woodman, Jack Lazar, and Anthony Bates 24 26 By: /s/ Patrice l. Bishop_________ Patrice L. Bishop 9430 West Olympic Blvd., Suite 400 Beverly Hills, CA 90212 Tel: (310) 209-2468 Fax: (310) 209-2087 Email: pbishop@ssbla.com Thomas J. McKenna GAINEY McKENNA & EGLESTON 440 Park Avenue South, 5th Floor New York, NY 10016 Tel: (212) 983-1300 Fax: (212) 983-0383 Email: tjmckenna@gme-law.com 13 17 STULL, STULL & BRODY Pursuant to Civil L.R. 5-1(i)(3), I, Patrice L. Bishop, attest that all other signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing. STIPULATION AND [PROPOSED] ORDER Case No. 3:16-cv-00232-JST /s/_Patrice L. Bishop 1 HONORABLE JON S. TIGAR UNITED STATES DISTRICT JUDGE 9 NO 10 DERED O OR IT IS S RT 11 ER H 12 n J u d ge J o 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND [PROPOSED] ORDER Case No. 3:16-cv-00232-JST R NIA 8 S . Ti ga r FO 7 July 19, 2016 Dated: _____________________ RT U O 6 S DISTRICT TE C TA ___________________________________________ LI 5 A 4 PURSUANT TO STIPULATION, IT IS SO ORDERED. S 3 UNIT ED 2 [Proposed] ORDER N F D IS T IC T O R C

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