Crago v. Charles Schwab & Co., Inc. et al
Filing
45
STIPULATION AND ORDER RE 44 for Extension of Time to File Amended Complaint. Signed by Judge Richard Seeborg on 1/12/17. (cl, COURT STAFF) (Filed on 1/12/2017)
1
2
3
4
5
6
7
8
9
10
Lionel Z. Glancy (SBN #134180)
Robert V. Prongay (SBN #270796)
Joshua L. Crowell (SBN #295411)
GLANCY PRONGAY & MURRAY LLP
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: (310) 201-9150
Facsimile: (310) 201-9160
Email: rprongay@glancylaw.com
J. Brandon Walker
Todd H. Henderson
BRAGAR EAGEL & SQUIRE, P.C.
885 Third Avenue, Suite 3040
New York, New York 10022
Telephone: (212) 308-5858
Facsimile: (212) 486-0462
Email: walker@bespc.com
11
12
Attorneys for Lead Plaintiffs
UNITED STATES DISTRICT COURT
13
NORTHERN DISTRICT OF CALIFORNIA
14
15
ROBERT CRAGO, Individually And On Behalf
Of All Others Similarly Situated,
Case No. 3:16-cv-3938-RS
16
Plaintiff,
17
18
19
20
21
22
JOINT STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION OF TIME TO
FILE AMENDED COMPLAINT
v.
THE CHARLES SCHWAB CORPORATION,
CHARLES SCHWAB & CO., INC., CHARLES
R. SCHWAB, and WALTER W. BETTINGER
II,
Defendants.
23
24
25
26
27
28
STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS
1
Lead Plaintiffs Robert Wolfson and Frank Pino (“Lead Plaintiffs”) and Defendants The
2
Charles Schwab Corp., Charles Schwab & Co., Inc., Charles R. Schwab, and Walter W. Bettinger II
3
(“Defendants”), by and through their respective counsel, have met and conferred and hereby
4
stipulate as follows:
5
6
WHEREAS, pursuant to a stipulated order entered by the Court on November 18, 2016
(ECF No. 41), Lead Plaintiffs’ amended complaint is due January 13, 2017;
7
WHEREAS, due to the recent illnesses of certain attorneys handling the case for Co-Lead
8
Counsel, Lead Plaintiffs sought Defendants’ consent to a one-week extension of time to file the
9
amended complaint;
10
WHEREAS, Lead Plaintiffs and Defendants have met and conferred about extending all
11
deadlines previously stipulated to in this action by one week and the parties mutually agree, with the
12
Court’s approval, that the new deadlines shall be as follows:
13
January 20, 2017:
Lead Plaintiffs Filing Amended Complaint
14
March 10, 2017:
Schwab’s Motion to Dismiss
15
April 21, 2017:
Lead Plaintiffs’ Opposition to Schwab’s Motion
16
May 19, 2017:
Schwab’s Reply
17
WHEREAS, the parties further agree that in light of the foregoing circumstances and in the
18
interest of judicial efficiency, administration and justice, as well as conservation of judicial and
19
private resources, the Initial Case Management Conference should be continued until after the Court
20
has decided Schwab’s motion to dismiss and there is an operative complaint on file; and
21
WHEREAS, this is the parties’ first request for an extension of any deadline in this case.
22
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, SUBJECT TO
23
APPROVAL BY THIS COURT, by these parties through their respective counsel of record, as
24
follows:
25
26
1.
Lead Plaintiffs’ deadline to file a new complaint will be January 20, 2017;
2.
Schwab’s deadline to file its motion to dismiss will be March 10, 2017;
27
28
-1STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS
1
2
3.
Lead Plaintiffs’ deadline to file its opposition to Schwab’s motion will be
April 21, 2017;
3
4.
Schwab’s deadline to file its reply to its motion will be May 19, 2017;
4
5.
The initial case management conference and all accompanying deadlines will be
5
6
continued until after the Court decides Schwab’s motion to dismiss and there is an operative
complaint on file; and
7
8
9
10
11
6.
The parties do not seek to reset these dates for the purpose of delay. The proposed
new dates will not have an effect on any pre-trial and trial dates as the Court has yet to schedule
these dates.
SO STIPULATED.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-2STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS
1
Dated: January 12, 2017
GLANCY PRONGAY & MURRAY LLP
2
By:
3
4
5
6
7
/s/ Joshua L. Crowell
Robert V. Prongay (#270796)
Joshua L. Crowell (#295411)
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: (310) 201-9150
Facsimile: (310) 201-9160
Email: info@glancylaw.com
Co-Lead Counsel for Lead Plaintiffs and the
Class
8
9
BRAGAR EAGEL & SQUIRE, P.C.
10
11
By:
12
13
14
15
16
/s/ J. Brandon Walker
J. Brandon Walker
Todd H. Henderson
885 Third Avenue, Suite 3040
New York, New York 10022
Telephone: (212) 308-5858
Facsimile: (212) 486-0462
walker@bespc.com
henderson@bespc.com
Co-Lead Counsel for Lead Plaintiffs and the
Class
17
18
19
20
Dated: January 12, 2017
ARNOLD & PORTER KAYE SCHOLER
LLP
21
22
By:
23
24
25
26
/s/ Gilbert R. Serota
Gilbert R. Serota
Three Embarcadero Center, 10th Floor
San Francisco, CA 94111-4024
Telephone: (415) 471-3170
Facsimile: (415) 471-3400
gilbert.serota@apks.com
Attorneys for Defendants
27
28
-3STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS
ATTESTATION
1
2
I, Joshua L. Crowell, am the ECF User whose identification and password are being used to
3
file this Proposed Order of Consolidation. In compliance with Local Rule 5-1(i)(3), I hereby attest
4
that Co-Lead Counsel for Plaintiffs, Robert Wolfson and Frank Pino, concurs in this filing.
5
6
DATED: January 12, 2017
/s/ Joshua L. Crowell
JOSHUA L. CROWELL
7
8
9
[PROPOSED] ORDER
10
11
12
13
14
15
Based on the parties’ stipulation and the good cause described therein, the Court GRANTS
this stipulation. The following schedule shall apply:
January 20, 2017:
Plaintiffs’ Deadline To File A New Complaint
March 10, 2017:
Schwab’s Deadline To File A Motion To Dismiss
April 21, 2017:
Plaintiffs’ Deadline To File An Opposition to Schwab’s
Motion
16
17
18
19
20
21
May 19, 2017:
Schwab’s Deadline To File Reply
The Court orders that the initial case management conference and all accompanying
deadlines will be continued until after the Court decides Schwab’s motion to dismiss;
IT IS SO ORDERED.
DATED: __________________
1/12/17
Hon. Richard Seeborg
U.S. District Court Judge
22
23
24
25
26
27
28
-4-
STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?