Crago v. Charles Schwab & Co., Inc. et al

Filing 87

STIPULATION AND ORDER RE 86 for Extension of Briefing Schedule. Signed by Judge Richard Seeborg on 9/25/17. (cl, COURT STAFF) (Filed on 9/25/2017)

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LIONEL Z. GLANCY (#134180)
[e-mail]
JOSHUA L. CROWELL (#295411)
[e-mail]
GARTH SPENCER
[e-mail]
GLANCY PRONGAY & MURRAY LLP
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
LAWRENCE P. EAGEL
[e-mail]
JEFFREY H. SQUIRE
[e-mail]
DAVID J. STONE
[e-mail]
TODD H. HENDERSON
[e-mail]
BRAGAR EAGEL & SQUIRE, P.C.
885 Third Avenue, Suite 3040
New York, New York 10022
Telephone: [phone]
Facsimile: [phone]
Attorneys for Lead Plaintiffs Robert Wolfson and Frank
Pino and Co-Lead Counsel for the Class

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
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ROBERT CRAGO, Individually And On Behalf
Of All Others Similarly Situated,

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Plaintiff,
v.

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CLASS ACTION
JOINT STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION OF BRIEFING
SCHEUDLE

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Case No. 3:16-cv-3938-RS

CHARLES SCHWAB & CO., INC., and THE
CHARLES SCHWAB CORPORATION,
Defendants.

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STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS

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Pursuant to Local Rule 6-2, Lead Plaintiffs Robert Wolfson and Frank Pino (“Lead
Plaintiffs”), and Defendants Charles Schwab & Co., Inc. and The Charles Schwab Corporation
(“Defendants” or “Schwab”; collectively, the “Parties”), by and through their respective counsel, for
good cause, hereby stipulate as follows:
WHEREAS, on June 12, 2017, the Court dismissed the Amended Class Action Complaint
with leave to amend (ECF No. 64);
WHEREAS, on July 26, 2017, the Court entered a stipulated order scheduling the briefing of
Defendants’ motion to dismiss (ECF No. 76);
WHEREAS, on August 3, 2017, the Court granted the request for an extension of time to
file an amended complaint until August 14, 2017 (ECF No. 80);
WHEREAS, on September 6, 2017, the Court continued the motion hearing previously set
for November 2, 2107, to November 9, 2017 (ECF No. 84), then to November 13 (ECF NO. 85);
WHEREAS, at Lead Plaintiffs’ request, Defendants have agreed to extend the briefing
schedule, and the Parties mutually agree, with the Court’s approval, that the new deadlines shall be
as follows:
October 4, 2017:

Opposition to motion to dismiss

October 25, 2017:

Reply in support of motion to dismiss

November 13, 1017: Hearing on motion to dismiss
WHEREAS, the Parties have previously requested and were granted extensions of time to
respond to the complaint (ECF No. 23), to continue the initial case management conference (ECF
No. 39), and to extend the time to file an amended complaint (ECF No. 80);
WHEREAS, the changes requested herein will not alter the hearing date for the motion to
dismiss or of any other deadlines already fixed by Court order, as this Court has yet to schedule pretrial and trial dates.
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, SUBJECT TO
APPROVAL BY THIS COURT, by the Parties, through their respective counsel of record, as
follows:

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-1STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS

1.

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October 4, 2017;
2.

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Schwab’s deadline to file the reply in support of its motion will be October 25, 2017;

5.

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Lead Plaintiffs’ deadline to file an opposition to Schwab’s motion will be

The hearing on Schwab’s motion to dismiss will be held on November 13, 2017, or

and

another date as determined by this Court.
IT IS SO STIPULATED.

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-2STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS

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Dated: September 25, 2017

GLANCY PRONGAY & MURRAY LLP

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By:

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/s/ Joshua L. Crowell
Joshua L. Crowell (#295411)
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Co-Lead Counsel for Lead Plaintiffs and the
Class

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BRAGAR EAGEL & SQUIRE, P.C.

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By:

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/s/ David J. Stone
David J. Stone
885 Third Avenue, Suite 3040
New York, New York 10022
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Co-Lead Counsel for Lead Plaintiffs and the
Class

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Dated: September 25, 2017

ARNOLD & PORTER KAYE SCHOLER
LLP

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/s/ Gilbert R. Serota
Gilbert R. Serota
Three Embarcadero Center, 10th Floor
San Francisco, CA 94111-4024
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Attorneys for Defendants

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By:

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-3STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS

ATTESTATION

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I, Joshua L. Crowell, am the ECF User whose identification and password are being used to

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file this Proposed Order of Consolidation. In compliance with Local Rule 5-1(i)(3), I hereby attest

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that Counsel for Defendants concur in this filing.

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DATED: September 25, 2017

/s/ Joshua L. Crowell
JOSHUA L. CROWELL

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STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS

[PROPOSED] ORDER

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Based on the Parties’ stipulation and the good cause described therein, the Court GRANTS
this stipulation. The following schedule shall apply:
October 4, 2017:

Motion

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Lead Plaintiffs’ Deadline to File Opposition to Schwab’s

October 25, 2017:

Schwab’s Deadline to File Reply in Support of Motion

November 13, 2017: Hearing for Schwab’s Motion to Dismiss
IT IS SO ORDERED.
9/25/17
DATED: __________________

Hon. Richard Seeborg
U.S. District Court Judge

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-5-

STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS