Leevan v. Credit Suisse International et al

Filing 62

ORDER by Judge Saundra Brown Armstrong Granting 61 Motion (ndr, COURT STAFF) (Filed on 6/25/2014)

Thomas L. Laughlin IV
1 Deborah Clark-Weintraub
2 SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
The Chrysler Building
3 405 Lexington Avenue, 40th Floor
New York, NY 10174
4 Tel: [phone]
Fax: [phone]
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Email: [e-mail]
[e-mail]
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7 Counsel for Lead Plaintiffs
[Additional counsel on signature page.]
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
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WILLARD A. SHARRETTE, DAVID
GOLDMAN, and ESTA GOLDMAN,
Individually and on Behalf of All Others
Similarly Situated,

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Plaintiffs,

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v.

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Case No. 4:13-cv-02783-SBA
STIPULATION AND ORDER
REGARDING PLAINTIFFS’ MOTION
FOR ADMINISTRATIVE RELIEF TO
FILE NUNC PRO TUNC AN
OVERSIZED BRIEF IN OPPOSITION
TO DEFENDANTS’ MOTION TO
DISMISS THE CONSOLIDATED
AMENDED COMPLAINT

CREDIT SUISSE INTERNATIONAL, a
foreign company; CREDIT SUISSE
SECURITIES (USA) LLC, a Delaware
limited liability company; and DOES 1-100, Hon. Saundra Brown Armstrong
Defendants.

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STIPULATION AND [PROPOSED] ORDER REGARDING PLAINTIFFS’ MOTION FOR

28 ADMINISTRATIVE RELIEF TO FILE NUNC PRO TUNC AN OVERSIZED BRIEF IN OPPOSITION
TO DEFENDANTS’ MOTION TO DISMISS THE CONSOLIDATED AMENDED COMPLAINT
4:13-cv-02783-SBA

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Pursuant to Civil Local Rules 7-11 and 7-12, Plaintiffs hereby submit this Stipulation and
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[Proposed] Order Regarding Their Motion for Administrative Relief to File Nunc Pro Tunc an
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Oversized Brief in Opposition to Defendants’ Motion to Dismiss the Consolidated Amended
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Complaint.
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WHEREAS, on April 4, 2014, Defendants filed a Motion to Dismiss the Consolidated
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Amended Complaint (ECF No. 53);
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WHEREAS, on June 10, 2014, Plaintiffs filed an Opposition to Defendants’ Motion to
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Dismiss the Consolidated Amended Complaint (ECF No. 58), which Opposition is four pages in
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excess of the page limit specified by this Court’s Standing Orders;
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WHEREAS, Plaintiffs notified Defendants of their intent to file a Motion for
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Administrative Relief to File Nunc Pro Tunc an Oversized Brief in Opposition to Defendants’
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Motion to Dismiss the Consolidated Amended Complaint; and
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WHEREAS, Defendants do not oppose Plaintiffs’ Motion for Administrative Relief to
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File Nunc Pro Tunc an Oversized Brief in Opposition to Defendants’ Motion to Dismiss the
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Consolidated Amended Complaint, as long as Defendants also receive an additional four pages
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for their reply brief;
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THEREFORE, IT IS HEREBY STIPULATED AND AGREED by all parties through
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their respective counsel of record, that:
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1.

Plaintiffs shall be granted the right to file nunc pro tunc an oversized brief in

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opposition to Defendant’s Motion to Dismiss the Consolidated Amended Complaint, which brief
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will be nineteen (19) pages in length; and
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2.

Defendants shall be granted the right to file a reply brief that shall not exceed

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fourteen (14) pages in length, a four-page increase commensurate with the additional pages
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granted to Plaintiffs.
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STIPULATION AND [PROPOSED] ORDER REGARDING PLAINTIFFS’ MOTION FOR

28 ADMINISTRATIVE RELIEF TO FILE NUNC PRO TUNC AN OVERSIZED BRIEF IN OPPOSITION
TO DEFENDANTS’ MOTION TO DISMISS THE CONSOLIDATED AMENDED COMPLAINT
4:13-cv-02783-SBA

1 STIPULATED AND AGREED TO:
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DATED: June 19, 2014

SCOTT+SCOTT, Attorneys at Law, LLP
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]

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Stephen J. Teti
SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
156 South Main Street
P.O. Box 192
Colchester, CT 06415
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Hal Cunningham
SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
707 Broadway, Suite 1000
San Diego, California 92101
Tel.: [phone]
Fax: [phone]
Email: [e-mail]

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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]

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Counsel for Lead Plaintiffs

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STIPULATION AND [PROPOSED] ORDER REGARDING PLAINTIFFS’ MOTION FOR

28 ADMINISTRATIVE RELIEF TO FILE NUNC PRO TUNC AN OVERSIZED BRIEF IN OPPOSITION
TO DEFENDANTS’ MOTION TO DISMISS THE CONSOLIDATED AMENDED COMPLAINT
4:13-cv-02783-SBA

1 DATE: June 19, 2014
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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]

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Counsel for Credit Suisse International and Credit
Suisse Securities (USA) LLC

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PURSUANT TO THIS STIPULATION, IT IS SO ORDERED
6/25/2014
DATED:__________________________

__________________________________________
HON. SAUNDRA BROWN ARMOSTRONG
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER REGARDING PLAINTIFFS’ MOTION FOR

28 ADMINISTRATIVE RELIEF TO FILE NUNC PRO TUNC AN OVERSIZED BRIEF IN OPPOSITION
TO DEFENDANTS’ MOTION TO DISMISS THE CONSOLIDATED AMENDED COMPLAINT
4:13-cv-02783-SBA

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CERTIFICATE OF SERVICE
I hereby certify that on June 19, 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.
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I certify under penalty of perjury under the laws of the United States of America that the

6 foregoing is true and correct.
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Executed this 19th day of June, 2014 at New York, New York.
/s/ Thomas L. Laughlin
Thomas L. Laughlin
SCOTT+SCOTT, Attorneys at Law, LLP
The Chrysler Building
405 Lexington Avenue, 40th Floor
New York, NY 10174
Tel: [phone]
Fax: [phone]
[e-mail]

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28 STIPULATION AND [PROPOSED] ORDER REGARDING PLAINTIFFS’ MOTION FOR
ADMINISTRATIVE RELIEF TO FILE NUNC PRO TUNC AN OVERSIZED BRIEF IN OPPOSITION
TO DEFENDANTS’ MOTION TO DISMISS THE CONSOLIDATED AMENDED COMPLAINT
4:13-cv-02783-SBA