Hampton v. Aqua Metals, Inc. et al

Filing 164

ORDER by Judge Haywood S. Gilliam, Jr. Granting 163 Stipulation Re Extension of Time to File Motion for Preliminary Approval of Settlement. Motions due by 7/6/2021. (ndrS, COURT STAFF) (Filed on 6/28/2021)

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Nicole Lavallee (SBN 165755)
Kristin J. Moody (SBN 206326)
BERMAN TABACCO
44 Montgomery Street, Suite 650
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Shannon L. Hopkins
Stephanie A. Bartone
LEVI & KORSINSKY, LLP
1111 Summer Street, Suite 304
Stamford, CT 06901
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Counsel for the Lead Plaintiff Plymouth County Group
and Co-Lead Counsel for the Class
[Additional Counsel on Signature Page]

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
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IN RE AQUA METALS, INC. SECURITIES )
LITIGATION
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This document Relates to:
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All Actions.
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Case No.: 4:17-cv-07142-HSG
CLASS ACTION
JOINT STIPULATION AND
ORDER RE EXTENSION OF TIME TO
FILE MOTION FOR PRELIMINARY
APPROVAL OF SETTLEMENT
Ctrm: 2, 4th Floor
Judge: Hon. Haywood S. Gilliam, Jr.

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[No.: 4:17-cv-07142-HSG] JOINT STIPULATION AND ORDER RE EXTENSION OF TIME TO FILE
MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT

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Court-appointed Lead Plaintiff, the Plymouth County Group (consisting of Plymouth County

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Retirement Association, Denis Taillefer and his private company, 1103371 Ontario Ltd.

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and Defendants Aqua Metals, Inc., Thomas Murphy, Selwyn Mould and Stephen R. Clarke

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,

,

), hereby stipulate and agree as follows.

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WHEREAS, on May 27, 2021, the Parties filed a joint stipulation with the Court stating

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they reached an agreement in principle to resolve all issues and claims involved in this litigation

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and requested a stay of the action for Plaintiff to file a motion for preliminary approval of

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settlement (ECF No. 160);

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WHEREAS, on May 28, 2021, this Court entered an order vacating all dates currently set

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in this Action, staying all proceedings for forty-five (45) days, and setting a date for the motion

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for preliminary approval to be filed within thirty (30) days (ECF No.161);

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WHEREAS,

s May 28, 2021 Order, the Plaintiff must file its motion

for preliminary approval of settlement by June 28, 2021;
WHEREAS, on June 2, 2021, Plaintiff circulated a draft Stipulation of Settlement to
Defendants for review;

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WHEREAS, the parties have agreed to all substantive terms, however, Defendants believe

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they may need additional time to review and get final agreement on the Stipulation of Settlement;

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WHEREAS, Plaintiff is unable to file the motion for preliminary approval of settlement

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until the Stipulation of Settlement has been executed;

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WHEREAS, the parties have met and conferred and have agreed that Plaintiff shall have

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an additional week, to July 6, 2021 (July 5, 2021 is a holiday), to file its motion for preliminary

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approval of settlement.

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THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among the parties
hereto, that:
1. Lead Plaintiff shall file its motion for preliminary approval no later than July 6, 2021.
IT IS SO STIPULATED.

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[No.: 4:17-cv-07142-HSG] JOINT STIPULATION AND ORDER RE EXTENSION OF TIME TO FILE
MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT
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DATED: June 25, 2021

Respectfully submitted,
BERMAN TABACCO
By:
/s/ Kristin J. Moody
Nicole Lavallee
Kristin J. Moody
44 Montgomery Street, Suite 650
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
LEVI & KORSINSKY, LLP
Shannon L. Hopkins
Stephanie A. Bartone
1111 Summer Street, Suite 403
Stamford, CT 06905
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Counsel for the Lead Plaintiff Plymouth County
Group and Co-Lead Counsel for the Class

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[No.: 4:17-cv-07142-HSG] JOINT STIPULATION AND ORDER RE EXTENSION OF TIME TO FILE
MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT
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DATED: June 25, 2021

GREENBERG TRAURIG, LLP

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By:

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Michael R. Hogue
4 Embarcadero Center, Suite 3000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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/s/ Robert A. Horowitz

Robert A. Horowitz
200 Park Avenue
New York, NY 10166
Telephone: [phone]
Email: [e-mail]

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Counsel for Defendants Aqua Metals, Inc.,
Selwyn Mould, and Thomas Murphy

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WILSON SONSINI GOODRICH & ROSATI

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By:

/s/ Dylan Grace Savage

Steven M. Schatz
Dylan Grace Savage
650 Page Mill Road
Palo Alto, CA 94304-1050
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Counsel for Defendant Stephen R. Clarke

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[No.: 4:17-cv-07142-HSG] JOINT STIPULATION AND ORDER RE EXTENSION OF TIME TO FILE
MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT
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E-FILING ATTESTATION
I, Kristin J. Moody, am the ECF User whose ID and password are being used to file this

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document. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that Robert A. Horowitz

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and Dylan Grace Savage have concurred in this filing.

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/s/ Kristin J. Moody
Kristin J. Moody

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[No.: 4:17-cv-07142-HSG] JOINT STIPULATION AND ORDER RE EXTENSION OF TIME TO FILE
MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT
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ORDER

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GOOD CAUSE HAVING BEEN SHOWN, it is hereby ordered that:

1. Lead Plaintiff shall file its motion for preliminary approval of settlement no later than
July 6, 2021.

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IT IS SO ORDERED.

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DATED:

6/28/2021

HON. HAYWOOD S. GILLIAM, JR.
UNITED STATES DISTRICT JUDGE

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[No.: 4:17-cv-07142-HSG] JOINT STIPULATION AND ORDER RE EXTENSION OF TIME TO FILE
MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT
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