Sgarlata v. PayPal Holdings, Inc. et al

Filing 55

STIPULATION AND ORDER re #54 CONTINUING INITIAL CASE MANAGEMENT CONFERENCE filed by PayPal Holdings, Inc. Case Management Statement due by 8/23/2018. Initial Case Management Conference set for 8/30/2018 09:30 AM in San Francisco, Courtroom 05, 17th Floor. Signed by Judge Edward M. Chen on 4/25/18. (bpf, COURT STAFF) (Filed on 4/25/2018)

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JAMES N. KRAMER (SBN 154709)
[e-mail]
ALEXANDER K. TALARIDES (SBN 268068)
[e-mail]
SUZETTE J. BARNES (SBN273116)
[e-mail]
ORRICK, HERRINGTON & SUTCLIFFE LLP
The Orrick Building
405 Howard Street
San Francisco, CA 94105-2669
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for PayPal Holdings, Inc.,
Daniel H. Schulman and John D. Rainey, Jr.
[additional counsel on signature page]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RONALD SGARLATA, Individually and on )
Behalf of All Others Similarly Situated,
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Plaintiffs,
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vs.
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PAYPAL HOLDINGS, INC., DANIEL H.
SCHULMAN, JOHN D. RAINEY JR., and )
)
HAMED SHAHBAZI,
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Defendants.
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)
)

Case No. 3:17-cv-06956-EMC
STIPULATION AND [PROPOSED]
ORDER CONTINUING INITIAL CASE
MANAGEMENT CONFERENCE

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STIPULATION AND [PROPOSED] ORDER
CONTINUING INITIAL CASE MANAGEMENT
CONFERENCE - (CASE NO. 3:17-CV-06956-EMC)

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WHEREAS, on March 5, 2018, the Court continued the Initial Case Management

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Conference (“CMC”) from March 8, 2018 to April 19, 2018, and set the deadline for the parties

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to file a joint CMC Statement to April 12, 2018;

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WHEREAS, on March 29, 2018, the parties filed a joint CMC Statement;

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WHEREAS on March 30, 2018 and April 6, 2018, the Court ordered that (i) Interim Co-

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Lead Plaintiffs shall file an amended complaint by June 12, 2018; (ii) Defendants shall file their

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responses to the amended complaint within thirty (30) days after the filing of the amended

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complaint; (iii) if any Defendant moves to dismiss the amended complaint, Interim Co-Lead

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Plaintiffs’ oppositions shall be due within thirty (30) days after the filing of the motion(s) to

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dismiss; and (iv) any replies shall be due within twenty (20) days after the filing of Interim Co-

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Lead Plaintiffs’ opposition;

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WHEREAS, on April 6, 2018, the Court continued the CMC from April 19, 2018 to April
26, 2018;

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WHEREAS, this action is governed by the Private Securities Litigation Reform Act of

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1995 (“PSLRA”), under which all “discovery and other proceedings” are automatically stayed

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pending determination of any motion(s) to dismiss,

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WHEREAS the parties have met and conferred, and agree to continue the CMC until after

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the Court has decided any and all motion(s) to dismiss any amended complaint filed by Interim

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Co-Lead Plaintiffs.

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NOW THEREFORE, the undersigned parties hereby stipulate and agree, and respectfully
request, that the Court enters an order as follows:
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The April 26, 2018 CMC is continued until after the Court decides any and all

motion(s) to dismiss any amended complaint filed by Interim Co-Lead Plaintiffs.

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STIPULATION AND [PROPOSED] ORDER
CONTINUING INITIAL CASE MANAGEMENT
CONFERENCE - (CASE NO. 3:17-CV-06956-EMC)

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Dated: April 23, 2018

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JAMES N. KRAMER
ALEXANDER K. TALARIDES
SUZETTE J. BARNES
Orrick, Herrington & Sutcliffe LLP

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/s/ Alexander K. Talarides
ALEXANDER K. TALARIDES

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Attorneys for Defendants
PayPal Holdings, Inc., Daniel H. Schulman, and John
D. Rainey, Jr.

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I, Alexander K. Talarides, am the ECF user whose ID and password are being used to file
this Stipulation and [Proposed] Order Continuing Initial Case Management Conference. In
compliance with General Order 45, X.B., I hereby attest that Jay L. Pomerantz has concurred in
this filing.
Dated: April 23, 2018

JAY L. POMERANTZ
Fenwick & West LLP

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/s/ Jay L. Pomerantz
JAY POMERANTZ

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Counsel for Defendant Hamed Shahbazi
I, Alexander K. Talarides, am the ECF user whose ID and password are being used to file
this Stipulation and [Proposed] Order Continuing Initial Case Management Conference. In
compliance with General Order 45, X.B., I hereby attest that Patrick V. Dahlstrom has concurred
in this filing.
Dated: April 23, 2018

JENNIFER PAFITI
JEREMY A. LIEBERMAN
PATRICK V. DAHLSTROM
LOUIS C. LUDWIG
Pomerantz LLP

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/s/ Patrick V. Dahlstrom
PATRICK V. DAHLSTROM

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Counsel for Interim Co-Lead Plaintiff Michael Eckert

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STIPULATION AND [PROPOSED] ORDER
CONTINUING INITIAL CASE MANAGEMENT
CONFERENCE - (CASE NO. 3:17-CV-06956-EMC)

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I, Alexander K. Talarides, am the ECF user whose ID and password are being used to file
this Stipulation and [Proposed] Order Continuing Initial Case Management Conference. In
compliance with General Order 45, X.B., I hereby attest that Jonathan Stern has concurred in
this filing.
Dated: April 23, 2018

LAURENCE ROSEN
JONATHAN STERN
The Rosen Law Firm, P.A.

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/s/ Jonathan Stern
JONATHAN STERN

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Counsel for Interim Co-Lead Plaintiff Edwin Bell

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[PROPOSED] ORDER

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DERED
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UNIT
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from 4/26/18 to 8/30/18 at 9:30 a.m. Joint CMC statement shall be
filed by 8/23/18.
S DISTRICT
Dated: __________________
________________________________________
TE
C
4/25/2018
TA
The Honorable Edward M. Chen
UNITED STATES DISTRICT JUDGE

R NIA

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Pursuant to the Stipulation of the Parties, IT IS SO ORDERED. The CMC is reset

FO

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F
D IS T IC T O
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STIPULATION AND [PROPOSED] ORDER
CONTINUING INITIAL CASE MANAGEMENT
CONFERENCE - (CASE NO. 3:17-CV-06956-EMC)