In re Lyft Inc. Securities Litigation

Filing 220

ORDER (as modified) by Judge Haywood S. Gilliam, Jr. Granting #219 Stipulation to Extend Briefing Schedule on Lead Plaintiff's Motion for Leave to file [Proposed] Second Amended Class Action Complaint. (ndr, COURT STAFF) (Filed on 11/18/2021)

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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]
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
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

MASTER FILE NO. 4:19-CV-02690-HSG

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This Document Relates to:

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ALL ACTIONS

JOINT STIPULATION AND
ORDER TO EXTEND BRIEFING
SCHEDULE ON LEAD PLAINTIFF’S
MOTION FOR LEAVE TO FILE
[PROPOSED] SECOND AMENDED
CLASS ACTION COMPLAINT (as
modified)

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ATTORNEYS AT LAW

STIP. TO EXTEND BRIEFING SCHEDULE ON PL.’S
MOT. FOR LEAVE TO FILE SECOND AM. COMPL.
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 (the “Plaintiff,” and together with the Lyft

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Defendants, the “Parties”), through their counsel, submit the following Joint Stipulation and

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[Proposed] Order To Extend Briefing Schedule on Lead Plaintiff’s Motion for Leave to File

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[Proposed] Second Amended Class Action Complaint (ECF No. 206).

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WHEREAS, on September 30, 2021, Lead Plaintiff Rick Keiner filed a Motion for Leave
to File [Proposed] Second Amended Class Action Complaint (the “Motion” or “Motion for
Leave”) (ECF No. 206);
WHEREAS, pursuant to the Court’s Scheduling Notes in effect when the Motion was
filed, the hearing on the Motion was set for February 3, 2022;

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WHEREAS, on October 14, 2021, pursuant to the Parties’ stipulation, the Court extended

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Defendants’ deadline to respond to the Motion until November 30, 2021, and Plaintiffs’ deadline

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to reply to the Motion until January 7, 2022;

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WHEREAS, the Parties have met and conferred and agree to extend the date for the filing

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of the Opposition from November 30, 2021, to December 20, 2021, and the date for the filing of

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the Reply from January 7, 2022, to January 18, 2022;

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WHEREAS, modest extensions of the deadlines for the Opposition and the Reply will

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permit the parties to continue meeting their concurrent discovery obligations efficiently, while

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making mutual reasonable accommodations in light of the upcoming holidays.

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WHEREAS, there will still be ample time for the Court to consider the Opposition and

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Reply prior to the February 3, 2022, hearing on the Motion, and this extension of time will not

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alter the date of any event or deadline already fixed by Court order;

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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 Leave will be modified as

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follows:

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ATTORNEYS AT LAW

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STIP. TO EXTEND BRIEFING SCHEDULE ON PL.’S
MOT. FOR LEAVE TO FILE SECOND AM. COMPL.
Lead Case No. 4:19-cv-02690-HSG

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December 20, 2021; and

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The Lyft Defendants shall file their Opposition to the Motion for Leave by

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Plaintiff shall file a Reply in support of his Motion for Leave by January 18,

2021.

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Dated: November 17, 2021

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Stipulated and agreed to by:

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BLOCK & LEVITON LLP

LATHAM & WATKINS LLP

/s/ Jeffrey C. Block
Jeffrey C. Block (admitted pro hac vice)
Jacob A. Walker (CA Bar No. 271217)
260 Franklin Street, Suite 1860
Boston, MA 02110
[phone] phone
[phone] fax
[e-mail]
[e-mail]

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

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Lead Counsel and Counsel for Plaintiff
and the Class

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]
Attorneys for Lyft 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

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ATTORNEYS AT LAW

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STIP. TO EXTEND BRIEFING SCHEDULE ON PL.’S
MOT. FOR LEAVE TO FILE SECOND AM. COMPL.
Lead Case No. 4:19-cv-02690-HSG

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FILER’S ATTESTATION

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Pursuant to Civil L. R. 5-1(h)(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: November 17, 2021

/s/ Colleen C. Smith
Colleen C. Smith

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PURSUANT TO STIPULATION, IT IS SO ORDERED except the Plaintiff shall file a
Reply in support of his Motion for Leave by January 18, 2022.
Date:

11/18/2021

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

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ATTORNEYS AT LAW

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STIP. TO EXTEND BRIEFING SCHEDULE ON PL.’S
MOT. FOR LEAVE TO FILE SECOND AM. COMPL.
Lead Case No. 4:19-cv-02690-HSG