Leevan v. Credit Suisse International et al

Filing 57

ORDER by Judge Saundra Brown Armstrong Granting 56 Stipulation. (ndr, COURT STAFF) (Filed on 5/29/2014)

SCOTT+SCOTT, Attorneys at Law, LLP
1 Deborah-Clark Weintraub
2 Thomas L. Laughlin IV
The Chrysler Building
3 405 Lexington Avenue, 40th Floor
New York, NY 10174
4 Tel: [phone]
Fax: [phone]
5 Email: [e-mail]
[e-mail]
6
7 LEWIS & ROBERTS, PLLC
Gary V. Mauney
8 James A. Robert III
One Southpark Center
9 6060 Piedmont Row Drive South, Suite 140
Charlotte, NC 28287
10
Tel: [phone]
11 Fax: [phone]
[e-mail]
12 [e-mail]
13 Counsel for Lead Plaintiffs
14
15
16
17
18
19

LATHAM & WATKINS LLP
Patrick E. Gibbs (183174)
Allison S. Davidson (267964)
140 Scott Drive
Menlo Park, California 94025
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]

20 Counsel for Credit Suisse International
and Credit Suisse Securities (USA) LLC
21
22

(Caption continued on next page)

23
24
25
26
27
STIPULATION, DECLARATION, AND [PROPOSED] ORDER EXTENDING DEADLINE FOR LEAD

28 PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS BY ONE WEEK

4:13-cv-02783-SBA

1

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

2
3
4
5
6
7
8
9
10
11
12

WILLARD A. SHARRETTE, DAVID
GOLDMAN, and ESTA GOLDMAN,
Individually and on Behalf of All Others
Similarly Situated,
Plaintiffs,
v.
CREDIT SUISSE INTERNATIONAL, a
foreign company, CREDIT SUISSE
SECURITIES (USA) LLC, a Delaware
limited liability company, and DOES 1-100,

Case No. 4:13-cv-02783-SBA
STIPULATION, DECLARATION, AND
[PROPOSED] ORDER EXTENDING
DEADLINE FOR LEAD PLAINTIFFS’
OPPOSITION TO DEFENDANTS’
MOTION TO DISMISS BY ONE WEEK
Hon. Saundra Brown Armstrong

Defendants.

13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
STIPULATION, DECLARATION, AND [PROPOSED] ORDER EXTENDING DEADLINE FOR LEAD

28 PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS BY ONE WEEK

4:13-cv-02783-SBA

1

WHEREAS, on December 5, 2013, this Court entered an order (ECF No. 43) appointing

2 Willard A. Sharrette, David Goldman, and Esta Goldman as Lead Plaintiffs;
3

WHEREAS, on December 24, 2013, the Court entered an order (ECF No. 46) providing

4 deadlines for which Lead Plaintiffs would be required to file an amended complaint, and by
5 which Defendants would be required to answer or otherwise respond to the amended complaint;
6

WHEREAS, on February 3, 2014, Lead Plaintiffs filed a Consolidated Amended

7 Complaint (ECF No. 48);
8

WHEREAS, on April 4, 2014, Defendants filed a Motion to Dismiss the Consolidated

9 Amended Complaint (ECF No. 53);
10

WHEREAS, pursuant to the Court’s December 24, 2013 order, Lead Plaintiffs are

11 required to file any opposition to Defendants’ Motion to Dismiss by June 3, 2014, and
12 Defendants are required to file any reply in further support of their Motion to Dismiss by July 3,
13 2014;
14

WHEREAS, Lead Plaintiffs requested that Defendants stipulate to a one-week extension

15 of the deadline to file an opposition to Defendants’ Motion to Dismiss, and Defendants agreed on
16 the condition that the deadline to file Defendants’ reply be pushed back by one week as well.
17

THEREFORE, IT IS HEREBY STIPULATED AND AGREED by all parties through

18 their respective counsel of record, that:
19

1.

Lead Plaintiffs shall be granted a one-week extension to file an opposition to

20 Defendants’ Motion to Dismiss, from June 3, 2014 to June 10, 2014; and
21

2.

The time for Defendants to file their reply in further support of their Motion to

22 Dismiss will also be extended by one week, from July 3, 2014 to July 10, 2014.
23
24
25
26
27
28 STIPULATION, DECLARATION, AND [PROPOSED] ORDER EXTENDING DEADLINE FOR LEAD
PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS BY ONE WEEK

1

4:13-cv-02783-SBA

1 STIPULATED AND AGREED TO:
2

DATED: May 29, 2014

3

By: /s/ Thomas L. Laughlin IV
Thomas L. Laughlin IV
Deborah-Clark Weintraub
SCOTT+SCOTT, Attorneys at Law, LLP
The Chrysler Building
405 Lexington Avenue, 40th Floor
New York, NY 10174
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]

4
5
6
7
8
9
10

LEWIS & ROBERTS, PLLC
Gary V. Mauney
James A. Robert III
One Southpark Center
6060 Piedmont Row Drive South, Suite 140
Charlotte, NC 28287
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]

11
12
13
14
15
16

Counsel for Lead Plaintiffs

17
18
19
20
21
22
23
24
25

SCOTT+SCOTT, Attorneys at Law, LLP

DATE: May 29, 2014

LATHAM & WATKINS LLP
By: /s/ Allison S. Davison
Allison S. Davidson (267964)
Patrick E. Gibbs (183174)
140 Scott Drive
Menlo Park, California 94025
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Counsel for Credit Suisse International and Credit
Suisse Securities (USA) LLC

26
27
28 STIPULATION, DECLARATION, AND [PROPOSED] ORDER EXTENDING DEADLINE FOR LEAD
PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS BY ONE WEEK

2

4:13-cv-02783-SBA

1

Pursuant to Local Rule 6-2, this Stipulation is supported by the following Declaration of

2 Thomas Laughlin.
3

DECLARATION OF THOMAS LAUGHLIN

4 I, Thomas Laughlin, declare:
5

1.

I am an attorney at Scott+Scott, Attorneys at Law, LLP, counsel for Plaintiffs in

6 this action. I have the principal responsibility for preparing Lead Plaintiffs’ brief in opposition to
7 Defendants’ Motion to Dismiss. I make this Declaration in support of the parties’ stipulation to
8 extend the deadline for Lead Plaintiffs’ opposition brief by one week.
9

2.

This is the first request for an extension of time.

10

3.

The parties have stipulated to this extension at my request. Although I have acted

11 with due diligence, several other matters have required my immediate attention in recent weeks,
12 including a bench trial ongoing in the District of Maine.
13

4.

14 3:00 p.m.

There is a case management conference presently scheduled for July 24, 2014 at
Defendants noticed the hearing for the Motion to Dismiss for July 15, 2014.

15 Therefore, it does not appear that the requested extension will impact the schedule in this case.
16

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on

17 May 29, 2014 at New York, New York.
/s/ Thomas L. Laughlin, IV
Thomas L. Laughlin, IV

18
19
20

PURSUANT TO THIS STIPULATION IT IS SO ORDERED.

21 DATED:
22
23

5/29/2014

HON. SAUNDRA BROWN ARMSTRONG
UNITED STATES DISTRICT JUDGE

24
25
26
27
28 STIPULATION, DECLARATION, AND [PROPOSED] ORDER EXTENDING DEADLINE FOR LEAD
PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS BY ONE WEEK

3

4:13-cv-02783-SBA

CERTIFICATE OF SERVICE

1
2

I hereby certify that on May 29, 2014, I caused the foregoing to be electronically filed

3 with the Clerk of the Court using the CM/ECF system which will send notification of such filing
4 to the email addresses denoted on the Electronic Mail Notice List.
5

I certify under penalty of perjury under the laws of the United States of America that the

6 foregoing is true and correct.
7
8
9
10
11
12
13

Executed this 29th day of May, 2014 at New York, New York.
/s/ Thomas L. Laughlin IV
Thomas L. Laughlin IV
SCOTT+SCOTT, Attorneys at Law, LLP
The Chrysler Building
405 Lexington Avenue, 40th Floor
New York, NY 10174
Tel: [phone]
Fax: [phone]
[e-mail]

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28 STIPULATION, DECLARATION, AND [PROPOSED] ORDER EXTENDING DEADLINE FOR LEAD
PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS BY ONE WEEK

4

4:13-cv-02783-SBA