Hoffman v. Intrexon Corporation et al

Filing 41

STIPULATION AND ORDER REGARDING DEADLINE FOR FILING CONSOLIDATED AMENDED COMPLAINT AND BRIEFING SCHEDULE FOR ANTICIPATED MOTION(S) TO DISMISS 40 : amended complaint due 9/22/2016, answer to amended complaint due 11/17/2016, any oppositions due 12 /23/2016; replies due 2/2/2017. Initial Case Management Conference continued until a date in early 2017 at the Court's convenience concurrent with the hearing on Defendants' anticipated motion(s) to dismiss or shortly thereafter. Signed by Judge Richard Seeborg on 8/2/2016. (afmS, COURT STAFF) (Filed on 8/2/2016)

1 LIONEL Z. GLANCY (#134180)
[e-mail]
2 ROBERT V. PRONGAY (#270796)
[e-mail]
3 JOSHUA L. CROWELL (#295411)
[e-mail]
4 GLANCY PRONGAY & MURRAY LLP
1925 Century Park East, Suite 2100
5 Los Angeles, California 90067
Telephone: [phone]
6 Facsimile: [phone]
Email:
[e-mail]
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Attorneys for Lead Plaintiff Joe Seppen
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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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13 IN RE INTREXON CORPORATION
SECURITIES LITIGATION
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Master File No. 3:16-cv-02398-RS
STIPULATION AND [PROPOSED]
ORDER REGARDING DEADLINE FOR
FILING CONSOLIDATED AMENDED
COMPLAINT AND BRIEFING
SCHEDULE FOR ANTICIPATED
MOTION(S) TO DISMISS

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Hon. Richard Seeborg
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338374.2

Stipulation Regarding Filing Consolidated Amended Complaint and Anticipated Motion(s) to Dismiss
Master File No. 3:16-cv-02398-RS

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WHEREAS, on June 29, 2016, the Court entered an Order requiring that after the appointment

2 of the lead plaintiff in this action, the lead plaintiff and defendants Intrexon Corporation, Randal J.
3 Kirk, and Rick L. Sterling (collectively, “Defendants”) shall promptly meet and confer regarding a
4 schedule for the filing of a consolidated complaint or designation of an operative complaint and a
5 briefing schedule for Defendants’ anticipated motion(s) to dismiss, and that the parties shall submit a
6 joint stipulation with a proposed schedule no later than ten business days following the appointment of
7 the lead plaintiff (ECF No. 18);
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WHEREAS, on July 25, 2016, the Court entered an Order consolidating the related actions,

9 appointing Joe Seppen as Lead Plaintiff, and approving Glancy Prongay & Murray LLP as Lead
10 Counsel for the putative class (ECF No. 36);
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WHEREAS, Lead Plaintiff and Defendants have met and conferred regarding a schedule for

12 the filing of a consolidated complaint or designation of an operative complaint and a briefing schedule
13 for Defendants’ anticipated motion(s) to dismiss;
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THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among the respective

15 parties hereto, subject to the approval of the Court, that:
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1.

Lead Plaintiff shall file the consolidated amended complaint by September 22, 2016;

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2.

Defendants shall answer or otherwise respond to the consolidated amended complaint

18 by November 17, 2016;
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3.

If Defendants move to dismiss the consolidated amended complaint, Lead Plaintiff

20 shall file its opposition(s) by December 23, 2016;
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4.

Defendants shall file their replies in support of any motion(s) to dismiss by February 2,

5.

The initial case management conference currently scheduled for October 13, 2016, at

22 2017;
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24 10:00 a.m., should be continued until a date in early 2017 at the Court's convenience concurrent with
25 the hearing on Defendants' anticipated motion(s) to dismiss or shortly thereafter.
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IT IS SO STIPULATED.

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338374.2

Stipulation Regarding Filing Consolidated Amended Complaint and Anticipated Motion(s) to Dismiss
Master File No. 3:16-cv-02398-RS

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1 Dated: August 1, 2016

GLANCY PRONGAY & MURRAY LLP

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/s/ Joshua L. Crowell
Joshua L. Crowell

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1925 Century Park East, Suite 2100
Los Angeles, CA 90067
Telephone: [phone]
Facsimile: 310-201-9160
Email: [e-mail]

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Attorneys for Lead Plaintiff Joe Seppen

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Dated: August 1, 2016
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WILSON SONSINI GOODRICH & ROSATI
PROFESSIONAL CORPORATION

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/s/ Joni Ostler
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Joni Ostler
650 Page Mill Road
Palo Alto, CA 94304
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Defendants Intrexon Corporation,
Randal J. Kirk, and Rick L. Sterling

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338374.2

Stipulation Regarding Filing Consolidated Amended Complaint and Anticipated Motion(s) to Dismiss
Master File No. 3:16-cv-02398-RS

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[PROPOSED] ORDER

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GOOD CAUSE HAVING BEEN SHOWN, it is hereby ordered that:

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1.

Lead Plaintiff shall file the consolidated amended complaint by September 22, 2016;

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2.

Defendants shall answer or otherwise respond to the consolidated amended complaint

5 by November 17, 2016;
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3.

If Defendants move to dismiss the consolidated amended complaint, Lead Plaintiff

7 shall file its opposition(s) by December 23, 2016;
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4.

Defendants shall file their replies in support of any motion(s) to dismiss by February 2,

5.

The initial case management conference currently scheduled for October 13, 2016, at

9 2017;
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11 10:00 a.m., should be continued until a date in early 2017 at the Court's convenience concurrent with
12 the hearing on Defendants' anticipated motion(s) to dismiss or shortly thereafter.
13 IT IS SO ORDERED.
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Dated:
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August 2, 2016

Honorable Richard Seeborg
United States District Judge

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338374.2

Stipulation Regarding Filing Consolidated Amended Complaint and Anticipated Motion(s) to Dismiss
Master File No. 3:16-cv-02398-RS

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