Leevan v. Credit Suisse International et al

Filing 20

ORDER by Judge Saundra Brown Armstrong Granting 12 Stipulation Extending Time to Respond and Continuing Case Management Conference (ndr, COURT STAFF) (Filed on 9/3/2013)

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LATHAM & WATKINS LLP
Patrick E. Gibbs (Bar No. 183174)
[e-mail]
Allison S. Davidson (Bar No. 267964)
[e-mail]
140 Scott Drive
Menlo Park, California 94025
Telephone: [phone]
Facsimile: +1.650.463.2600

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Attorneys for Defendants
Credit Suisse International and Credit
Suisse Securities (USA) LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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CASE NO.: 4:13-cv-02783-SBA
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MARK LEEVAN, individually and on behalf
of all others similarly situated,

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Plaintiff,

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STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO RESPOND AND
CONTINUING CASE MANAGEMENT
CONFERENCE

v.
CREDIT SUISSE INTERNATIONAL, a
foreign company; CREDIT SUISSE
SECURITIES (USA) LLC, a Delaware
limited liability company; and DOES 1-100

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Defendants.
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A T T O R N E Y S A T L AW
S I L I C O N V AL L E Y

STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO
RESPOND AND CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO. 4:13-cv-02783-SBA

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WHEREAS, Plaintiff Mark Leevan filed a Complaint against Defendants Credit Suisse
International and Credit Suisse Securities (USA) LLC on June 17, 2013 (the “Action”);

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WHEREAS, Defendant Credit Suisse Securities (USA) LLC was served with the
summons and complaint on July 17, 2013;

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WHEREAS, the undersigned parties anticipate that additional complaints may be filed,
and a Lead Plaintiff and Lead Counsel will need to be appointed;

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WHEREAS, the case management conference is currently scheduled before this Court on
September 18, 2013 at 2:30 PM;

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NOW, THEREFORE, in the interest of judicial economy and good cause showing, the

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parties, by and through their undersigned counsel of record, hereby agree and stipulate, and the

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Court hereby orders, as follows:

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(1)

Defendants need not respond to the complaint filed on June 17, 2013;

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(2)

After the appointment of a Lead Plaintiff and Lead Counsel, Defendants and Lead

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Plaintiff shall meet and confer to determine a schedule for the filing of an amended complaint,

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and Defendants’ response thereto. The parties will file a stipulated schedule for approval by the

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Court; and

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(3)

The case management conference currently scheduled for September 28, 2013 at

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2:30 PM shall be continued until January 16, 2014 at 3:00 PM, with the other dates set by the

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Order Setting Initial Case Management Conference and ADR Deadlines continued accordingly;

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and

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(4)

No party is waiving any rights, claims, or defenses of any kind except as

expressly stated herein.
The parties respectfully request that the Court enter an Order approving this Stipulation.

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A T T O R N E Y S A T L AW
S I L I C O N V AL L E Y

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO
RESPOND AND CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO. 4:13-cv-02783-SBA

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IT IS SO STIPULATED.

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Respectfully submitted,

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Dated: August 22, 2013

LATHAM & WATKINS LLP

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By: /s/ Patrick E. Gibbs
Patrick E. Gibbs
Attorneys for Defendants
CREDIT SUISSE
INTERNATIONAL AND CREDIT
SUISSE SECURITIES (USA) LLC

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Dated: August 22, 2013

NASSIRI & JUNG LLP

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By: /s/ Kassra P. Nassiri
Kassra P. Nassiri
Attorneys for Plaintiff
MARK LEEVAN

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED. The parties shall meet and
confer prior to the conference and
Dated: ___________________________ shall prepare a joint Case Management
______________________________
Conference Statement which shall be filed THE HONORABLE
no later than seven (7) days prior
SAUNDRA B. the Standing Order For
to the Case Management Conference that complies with ARMSTRONG
United States the Standing Order of
All Judges Of The Northern District Of California andDistrict Judge
this Court. Plaintiffs shall be responsible for filing the statement as well
as for arranging the conference call. All parties shall be on the line and
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shall call [phone] at the above indicated date and time.

9/3/2013
Dated: _______________________

______________________________
THE HONORABLE
SAUNDRA B. ARMSTRONG
United States District Judge

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A T T O R N E Y S A T L AW
S I L I C O N V AL L E Y

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO
RESPOND AND CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO. 4:13-cv-02783-SBA

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ATTESTATION CLAUSE

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I, Patrick Gibbs, am the ECF User whose identification and password are being used to

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file this Stipulation and [Proposed] Order Extending Time to Respond and Continuing Case

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Management Conference pursuant to Civil Local Rule 5-1. I hereby attest that Kassra Nassiri

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has concurred in this filing. I declare under penalty of perjury under the laws of the United States

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of America that the foregoing is true and correct. Executed this 22 day of August, 2013 at Menlo

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Park, California.

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By: /s/ Patrick E. Gibbs
Patrick E. Gibbs
Attorneys for Defendants
CREDIT SUISSE
INTERNATIONAL AND CREDIT
SUISSE SECURITIES (USA) LLC

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A T T O R N E Y S A T L AW
S I L I C O N V AL L E Y

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO
RESPOND AND CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO. 4:13-cv-02783-SBA