In re Lyft Inc. Securities Litigation

Filing 102

ORDER by Judge Haywood S. Gilliam, Jr. Granting #100 Stipulation to Extend Briefing Schedule on Plaintiff's Motion for Class Certification. (ndrS, COURT STAFF) (Filed on 10/13/2020)

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LATHAM & WATKINS LLP
Matthew Rawlinson (SBN 231890)
140 Scott Drive
Menlo Park, California 94025
T: [phone] / F: [phone]
[e-mail]
Elizabeth Deeley (SBN 230798)
505 Montgomery Street, Suite 2000
San Francisco, California 94111
T: [phone] / F: [phone]
[e-mail]
Andrew B. Clubok (pro hac vice)
Susan E. Engel (pro hac vice)
555 Eleventh Street, NW, Suite 1000
Washington, D.C. 20004
T: [phone] / F: [phone]
[e-mail]
[e-mail]
Colleen C. Smith (SBN 231216)
12670 High Bluff Drive
San Diego, California 92130
T: [phone] / F: [phone]
[e-mail]
Attorneys for Defendants Lyft, Inc., Logan Green,
John Zimmer, Brian Roberts, Prashant (Sean)
Aggarwal, Jonathan Christodoro, Ben Horowitz,
Valerie Jarrett, David Lawee, Hiroshi Mikitani, Ann
Miura-Ko, and Mary Agnes (Maggie) Wilderotter
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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In re LYFT, INC. SECURITIES
LITIGATION

Master File No. 4:19-cv-02690-HSG
CLASS ACTION

This Document Relates to:
ALL ACTIONS

JOINT STIPULATION AND
ORDER TO EXTEND BRIEFING
SCHEDULE ON PLAINTIFF’S
MOTION FOR CLASS
CERTIFICATION

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ATTORNEYS AT LAW
SAN FRANCISCO

JOINT STIP. AND ORDER TO EXTEND
SCHED. ON PLAINTIFF’S MOT. FOR CLASS CERT.
BRIEFING
CASE NO. 4:19-CV-02690-HSG

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Pursuant to Local Rules 6-2 and 7-12, Defendants Lyft, Inc., Logan Green, John Zimmer,

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Brian Roberts, Prashant (Sean) Aggarwal, Jonathan Christodoro, Ben Horowitz, Valerie Jarrett,

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David Lawee, Hiroshi Mikitani, Ann Miura-Ko, and Mary Agnes Wilderotter (the “Lyft

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Defendants”) and Lead Plaintiff, Rick Keiner (“Plaintiff”, and together with the Lyft Defendants,

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the “Parties”), through their counsel, submit the following Joint Stipulation and [Proposed] Order

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To Extend Briefing Schedule on Plaintiff’s Motion for Class Certification.

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WHEREAS, on March 26, 2020, the Court issued a Scheduling Order setting a briefing

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schedule for Plaintiff’s amended complaint and Defendants’ motion to dismiss per the Parties’

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joint proposal (ECF No. 72);

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WHEREAS, on April 16, 2020, pursuant to the Scheduling Order, Plaintiff filed the

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Consolidated Amended Class Action Complaint for Violation of the Federal Securities Laws (the

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“Complaint”) (ECF No. 74);

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WHEREAS, on May 17, 2020, pursuant to the Scheduling Order, the Lyft Defendants
filed their Motion to Dismiss the Complaint (ECF No. 78);
WHEREAS, on June 11, 2020, pursuant to the Scheduling Order, Plaintiff filed his
opposition to the Lyft Defendants’ Motion to Dismiss the Complaint (ECF No. 84);

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WHEREAS, on June 24 ,2020, the Court granted the Parties’ Joint Stipulation to Extend

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the Briefing Schedule On Lyft Defendants’ Motion to Dismiss (the “Briefing Extension Order”)

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(ECF. No. 87);

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ATTORNEYS AT LAW
SAN FRANCISCO

WHEREAS, pursuant to the Briefing Extension Order, the Lyft Defendants filed their
Reply in Support of Motion to Dismiss the Complaint on July 9, 2020 (ECF. No. 88);
WHEREAS, on September 8, 2020, the Court issued its Order Granting In Part and
Denying in Part Defendants’ Motion to Dismiss (ECF No. 96);
WHEREAS, on September 25, 2020, Plaintiff filed his Motion for Class Certification
(ECF No. 98);
WHEREAS, the Lyft Defendants’ Opposition to the Motion for Class Certification (the
“Opposition”) is currently due to be filed on October 9, 2020;
WHEREAS, to accommodate for the press of business and ensure adequate time for
JOINT STIP. AND ORDER TO EXTEND
1 SCHED. ON PLAINTIFF’S MOT. FOR CLASS CERT.
BRIEFING
CASE NO. 4:19-CV-02690-HSG

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briefing, counsel for the Parties have met and conferred, and agree to extend the date for the

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Opposition from October 9, 2020 to January 12, 2021; the date for Plaintiff’s Reply from

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October 16, 2020 to January 22, 2021; and the hearing currently set for December 17, 2020 at

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2:00 p.m. shall be set for February 4, 2021 at 2:00 p.m., or a date otherwise set by the Court.

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WHEREAS, this extension of time will not alter the date of any event or deadline already
fixed by Court order;
WHEREAS, this stipulation is not intended to operate as an admission of any factual

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allegation or legal conclusion and is submitted subject to and without waiver of any right,

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defense, affirmative defense, or objection;

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NOW, THEREFORE, pursuant to Civil Local Rule 6-2, the Parties hereby stipulate,

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subject to Court approval, that the briefing schedule for the Motion for Class Certification will be

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modified as follows:

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1.

The Lyft Defendants shall file their Opposition to the Motion for Class

Certification by January 12, 2021.

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2.

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January 22, 2021.

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3.

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Plaintiff shall file a Reply in support of his Motion for Class Certification by

The noticed date for a hearing on the Motion for Class Certification shall be set

for February 4, 2021 at 2:00 p.m., or a date otherwise set by the Court.

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Stipulated and agreed to by:

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Date: October 8, 2020

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ATTORNEYS AT LAW
SAN FRANCISCO

JOINT STIP. AND ORDER TO EXTEND
2 SCHED. ON PLAINTIFF’S MOT. FOR CLASS CERT.
BRIEFING
CASE NO. 4:19-CV-02690-HSG

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BLOCK & LEVITON LLP

LATHAM & WATKINS LLP

/s/ Jacob A. Walker __________
Jacob A. Walker (CA Bar. No. 271217)
260 Franklin Street, Suite 1860
Boston, MA 02110
[e-mail]

/s/ Colleen C. Smith____________
Colleen C. Smith (CA Bar. No. 231216)
12670 High Bluff Drive
San Diego, CA 92130
[e-mail]

Lead Counsel and Counsel for Plaintiff

Matthew Rawlinson (CA Bar. No. 231890)
140 Scott Drive
Menlo Park, CA 94025
T: [phone] / F: [phone]
[e-mail]
Elizabeth Deeley (CA Bar. No. 230798)
505 Montgomery Street, Suite 2000
San Francisco, CA 94111
T: [phone] / F: [phone]
[e-mail]
Andrew B. Clubok (pro hac vice)
Susan E. Engel (pro hac vice)
555 Eleventh Street, NW, Suite 1000
Washington, D.C. 20004
T: [phone] / F: [phone]
[e-mail]
[e-mail]
Counsel for Defendants Lyft, Inc., Logan
Green, John Zimmer, Brian Roberts,
Prashant Aggarwal, Jonathan
Christodoro, Ben Horowitz, Valerie
Jarrett, David Lawee, Hiroshi Mikitani,
Ann Miura-Ko, and Mary Agnes
Wilderotter

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ATTORNEYS AT LAW
SAN FRANCISCO

JOINT STIP. AND ORDER TO EXTEND
3 SCHED. ON PLAINTIFF’S MOT. FOR CLASS CERT.
BRIEFING
CASE NO. 4:19-CV-02690-HSG

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FILER’S ATTESTATION
Pursuant to Civil L. R. 5-1(i)(3), regarding signatures, I hereby attest that concurrence in
the filing of the document has been obtained from all of the signatories above.

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Dated: October 8, 2020

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/s/_Colleen C.Smith____________
Colleen C. Smith
*

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PURSUANT TO STIPULATION, IT IS SO ORDERED except the noticed date for a hearing on
the Motion for Class Certification shall be set for February 18, 2021 at 2:00 p.m.
Date: 10/13/2020

_______________________________
HONORABLE HAYWOOD S. GILLIAM, JR.
U.S. DISTRICT JUDGE

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ATTORNEYS AT LAW
SAN FRANCISCO

JOINT STIP. AND ORDER TO EXTEND
4 SCHED. ON PLAINTIFF’S MOT. FOR CLASS CERT.
BRIEFING
CASE NO. 4:19-CV-02690-HSG