In re VERISIGN, INC. DERIVATIVE LITIGATION

Filing 120

STIPULATION AND ORDER RESCHEDULING CASE MANAGEMENT CONFERENCE re 119 Stipulation filed by VeriSign Inc. Signed by Judge Phyllis J. Hamilton on 11/24/08. (nah, COURT STAFF) (Filed on 11/24/2008)

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CHRISTOPHER H. McGRATH (SB# 149129) [e-mail] KIMBERLEY A. DONOHUE (SB# 247027) [e-mail] PAUL, HASTINGS, JANOFSKY & WALKER LLP 4747 Executive Drive, 12th Floor San Diego, CA 921210 Telephone: [phone] Facsimile: [phone] THOMAS A. ZACCARO (SB# 183241) [e-mail] PAUL, HASTINGS, JANOFSKY & WALKER LLP 515 South Flower Street, 25th Floor Los Angeles, CA 90074-2228 Telephone: [phone] Facsimile: [phone] EDWARD HAN (SB# 196924) [e-mail] PAUL, HASTINGS, JANOFSKY & WALKER LLP 55 Second Street, 24th Floor San Francisco, CA 94105 Telephone: [phone] Facsimile: [phone] Attorneys for Nominal Defendant VeriSign, Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

In re VERISIGN, INC. DERIVATIVE LITIGATION

MASTER FILE NO. C-06-4165-PJH STIPULATION AND [PROPOSED] ORDER RESCHEDULING CASE MANAGEMENT CONFERENCE Judge: Ctrm: Hon. Phyllis J. Hamilton 3, 17th Floor

This Document Relates To: ALL ACTIONS.

Master File No. C-06-4165-PJH

STIP & [PROPOSED] ORDER RESCHEDULING CMC

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The parties, by their undersigned counsel, hereby stipulate to the following: WHEREAS, on September 14, 2007, the Court granted the motion by KPMG LLP to compel arbitration of the claims against it and granted the other defendants' respective motions to dismiss in the above-captioned matter; WHEREAS, on October 12, 2007, the Court granted the plaintiffs' administrative motion to enlarge the time to file the second amended complaint, and ordered that the second amended complaint be filed by November 16, 2007 with defendants' responses filed by December 18, 2007; WHEREAS, the plaintiffs filed the Verified Second Amended Shareholder Derivative Complaint on November 16, 2007 ("SAC"); WHEREAS, on May 13, 2008, the Court granted the parties' stipulation to (1) set a schedule for the filing of defendants' responses to the SAC, and (2) schedule a case management conference on June 19, 2008 to discuss the progress of settlement negotiations; WHEREAS, on June 11, 2008, the Court granted the parties' stipulation to reschedule the case management conference to July 24, 2008; WHEREAS, there is a related state court consolidated putative class action entitled In re VeriSign, Inc. Options Litigation, Master Case No. 1-07-CV-085890, pending in the California State Superior Court, Santa Clara County ("Parallel State Court Class Action"), before the Honorable Jack Komar, with many of the same named defendants and similar underlying allegations; WHEREAS, due to the state court's continuance of the hearing on defendants' motions to dismiss (demurrers) in the Parallel State Court Class Action, the Court granted the parties' stipulation to reschedule the case management conference to August 28, 2008; WHEREAS, a hearing on the defendants' motions to dismiss (demurrers) the Parallel State Court Class Action complaint was held on August 1, 2008, at which time Judge Komar granted defendants' motions to dismiss (demurrers) and granted plaintiff leave to amend the complaint;

Master File No. C-06-4165-PJH

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STIP & [PROPOSED] ORDER RESCHEDULING CMC

11/24/08

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