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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Patrice L. Bishop (182256)
[e-mail]
STULL, STULL & BRODY
9430 W. Olympic Blvd., Suite 400
Beverly Hills, CA 90212
Tel: [phone]
Fax: [phone]

Counsel for Plaintiff Majesty Palms, LLLP
[Additional Counsel on Signature Page]

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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JOSEPH BODRI, Individually and On
Behalf of All Others Similarly Situated,
v.

Plaintiff,

GOPRO, INC., NICHOLAS WOODMAN,
and JACK LAZAR,
Defendants.

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STIPULATION AND [PROPOSED] ORDER
Case No. 3:16-cv-00232-JST

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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

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Pursuant to Civil Local Rules 3-12, 7-11 and 7-12, the Parties in each of the above-entitled

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actions, by and through their counsel, hereby stipulate to the following:

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Investment”) pursuant to the Private Securities Litigation Reform Act of 1995 (“PSLRA”) as lead

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between July 21, 2015, and January 13, 2016 (Dkt. No. 76);

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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

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Palms”) pursuant to the PSLRA as lead plaintiff in this action to represent a putative class of

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WHEREAS, Camia Investment’s and Majesty Palms’ amended pleadings were due to be

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investors who purchased GoPro securities between November 26, 2014, and July 20, 2015 (id.);

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filed on June 21, 2016, Defendants’ motions to dismiss were due on August 22, 2016, responses in

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motions to dismiss were due on November 21, 2016, and a hearing on the motions to dismiss was

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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

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extension of 30 days to file an amended complaint (Dkt. No. 80);

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Violations of the Federal Securities Laws (Dkt. No. 81);

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Palms’ administrative motion and requested a single briefing schedule and hearing date for its

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No. 84);

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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

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for a 30-day extension of the due date to file its amended complaint, resulting in the complaint

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WHEREAS, on June 28, 2016, the Court also ordered the parties to meet and confer

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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

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WHEREAS, the Parties have met and conferred and agreed on the following schedule in

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light of the Court’s order and in consideration of fairness to all parties;

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that:

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Complaint for Violations of the Federal Securities Laws without prejudice as to further

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Investment’s complaint, except that Defendants reserve their right to object to such further

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IT IS HEREBY STIPULATED, by and between the undersigned counsel for the Parties,
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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;
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Defendants shall have until September 26, 2016, to respond to Camia Investment’s

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If Defendants’ respond by moving to dismiss Camia Investment’s and Majesty

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and Majesty Palms’ complaints; and

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Palms’ complaints:

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Plaintiffs shall have until November 16, 2016, to file responses in

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Defendants shall have until December 22, 2016, to file replies in support of

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The Court shall hold hearings on the motions to dismiss at its earliest

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opposition to the motions to dismiss;

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the motions to dismiss; and

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convenience after briefing is complete.

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Dated: July 18, 2016

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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: [phone]
Fax: [phone]
Email: [e-mail]

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Michael I. Fistel , Jr.
Johnson & Weaver, LLP
40 Powder Springs Street
Marietta, GA 30064
Tel: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Camia Investment LLC

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Dated: July 18, 2016

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Attorneys for Plaintiff Majesty Palms, LLLP
Dated: July 18, 2016

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FENWICK & WEST LLP

By: /s/Catherine D. Kevane _______
Catherine D. Kevane
555 California Street, 12th Floor
San Francisco, California 94104
Tel: [phone]
Fax: [phone]
Email: [e-mail]

Attorneys for Defendants
GoPro, Inc., Nicholas Woodman,
Jack Lazar, and Anthony Bates

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By: /s/ Patrice l. Bishop_________
Patrice L. Bishop
9430 West Olympic Blvd., Suite 400
Beverly Hills, CA 90212
Tel: [phone]
Fax: [phone]
Email: [e-mail]

Thomas J. McKenna
GAINEY McKENNA & EGLESTON
440 Park Avenue South, 5th Floor
New York, NY 10016
Tel: [phone]
Fax: [phone]
Email: [e-mail]

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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

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HONORABLE JON S. TIGAR
UNITED STATES DISTRICT JUDGE

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DERED

O OR
IT IS S

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J u d ge J o

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STIPULATION AND [PROPOSED] ORDER
Case No. 3:16-cv-00232-JST

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S . Ti ga r

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July 19, 2016
Dated: _____________________

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S DISTRICT
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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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UNIT
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[Proposed] ORDER

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