In re Lyft Inc. Securities Litigation

Filing 113

ORDER by Judge Haywood S. Gilliam, Jr. Granting #112 Stipulation to Extend Briefing Schedule on Plaintiff's Motion for Class Certification. (ndrS, COURT STAFF) (Filed on 1/7/2021)

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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]

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Attorneys for Defendants Lyft, Inc., Logan
Green, John Zimmer, Brian Roberts, Prashant
(Sean) Aggarwal, Ben Horowitz, Valerie Jarrett,
David Lawee, Hiroshi Mikitani, Ann Miura-Ko,
and Mary Agnes (Maggie) Wilderotter and NonParty Jonathan Christodoro

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Additional Counsel on Signature Page

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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In re LYFT INC. SECURITIES LITIGATION

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This Document Relates to:

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ALL ACTIONS

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MASTER FILE NO. 4:19-CV-02690-HSG
JOINT STIPULATION AND
ORDER TO EXTEND BRIEFING
SCHEDULE ON PLAINTIFF’S
MOTION FOR CLASS
CERTIFICATION

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ATTORNEYS AT LAW
SAN FRANCISCO

STIP. AND ORDER TO EXTEND
BRIEFING SCHEDULE
Lead 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 September 25, 2020, Plaintiff filed a Motion for Class Certification (ECF
No. 98);
WHEREAS, the Lyft Defendants’ Opposition to the Motion for Class Certification (the
“Opposition”) was originally due to be filed on October 9, 2020;

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WHEREAS, the Parties agreed to extend the date for the Opposition from October 9, 2020

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to January 12, 2021 and the date for Plaintiff’s Reply in support of his Motion for Class

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Certification (the “Reply”) from October 16, 2020 to January 22, 2021 (ECF No. 100);

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WHEREAS, this Court entered the stipulation as an order of the Court on October 13, 2020

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and set a date for hearing on the Motion for Class Certification for February 18, 2021 at 2:00 p.m.

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(ECF No. 102);

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WHEREAS, on December 29, 2020 the Court rescheduled the date for a hearing on the
Motion for Class Certification to March 11, 2021 at 2:00 p.m. (ECF No. 105);

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WHEREAS, in light of what the Lyft Defendants believe to be the complex issues involved

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in the Motion for Class Certification and to accommodate the Lyft Defendants’ request for

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adequate time for addressing these issues and for briefing and for Plaintiff to have adequate time

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

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Opposition from January 12, 2021 to January 19, 2021 and the date for Plaintiff’s Reply from

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January 22, 2021 to February 5, 2021;

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WHEREAS, this extension of time will not alter the date of any event or deadline already
fixed by Court order;

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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, defense,

ATTORNEYS AT LAW
SAN FRANCISCO

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JOINT STIP. AND PO TO EXTEND BRIEFING
SCHED. ON PLAINTFF’S MOT. FOR CLASS CER
Lead Case No. 4:19-cv-02690-HSG

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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 19, 2021.

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2.

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

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February 5, 2021.

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Stipulated and agreed to by:

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Date: January 6, 2021

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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]

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Elizabeth Deeley (CA Bar. No. 230798)
505 Montgomery Street, Suite 2000
San Francisco, CA 94111
T: [phone] / F: [phone]
[e-mail]

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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]

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Counsel for Defendants Lyft, Inc., Logan
Green, John Zimmer, Brian Roberts,

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ATTORNEYS AT LAW
SAN FRANCISCO

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JOINT STIP. AND ORDER TO EXTEND
SCHED. ON PLAINTFF’S MOT. FOR CLASS CERT.
BRIEFING
Case No. 4:19-cv-02690-HSG

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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

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JOINT STIP. AND ORDER TO EXTEND
SCHED. ON PLAINTFF’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: January 6, 2021

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/s/Colleen C. Smith
Colleen C. Smith
*

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Date: 1/7/2021

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

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ATTORNEYS AT LAW
SAN FRANCISCO

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JOINT STIP. AND PO TO EXTEND BRIEFING
SCHED. ON PLAINTFF’S MOT. FOR CLASS CERT.
Case No. 4:19-cv-02690-HSG