IN RE LYFT, INC. DERIVATIVE LITIGATION

Filing 66

ORDER by Judge Haywood S. Gilliam, Jr. GRANTING 64 Stipulation as to Dates for Motions for Final Settlement Approval and Attorneys' Fees. Motions due by 12/6/2024 Responses due by 12/13/2024Replies due by 12/20/2004 Motion Hearing set for 2/6/2025 02:00 PM in Oakland, Courtroom 2, 4th Floor before Judge Haywood S. Gilliam Jr. (ndr, COURT STAFF) (Filed on 10/24/2024)

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LEVI & KORSINSKY, LLP
Adam Apton
1160 Battery Street East Suite 100 - #3425
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Gregory M. Nespole (pro hac vice)
33 Whitehall Street, 17th Floor
New York, NY 10004
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
THE BROWN LAW FIRM, P.C.
Robert C. Moest, Of Counsel, SBN 62166
2530 Wilshire Boulevard, Second Floor
Santa Monica, California 90403
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Timothy Brown (pro hac vice)
240 Townsend Square
Oyster Bay, NY 11771
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Co-Lead Counsel for Plaintiffs
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
IN RE LYFT, INC. DERIVATIVE
LITIGATION

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This Document Relates to:

Lead Case No. 4:20-cv-09257-HSG
STIPULATION AND ORDER AS TO
DATES FOR MOTIONS
FOR FINAL SETTLEMENT APPROVAL
AND ATTORNEYS’ FEES

ALL ACTIONS

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WHEREAS, on October 16, 2024, the Court entered its Order Granting Plaintiffs’ Unopposed

27 Motion for Preliminary Approval of Settlement (the “Preliminary Approval Order,” Dkt. 62); and
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-1STIPULATION AND ORDER AS TO DATES FOR MOTIONS FOR FINAL
SETTLEMENT APPROVAL AND ATTORNEYS’ FEES

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WHEREAS, the Preliminary Approval Order directs the parties to, inter alia, meet and confer

2 and stipulate to a schedule of dates for certain events in connection with Plaintiffs’ forthcoming
3 motions for final settlement approval and attorneys’ fees; and
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WHEREAS, the parties have met and conferred as directed by the Court.
NOW, THEREFORE, the parties stipulate and agree to the following deadlines subject to the

7 approval of the Court:
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Event

Date

Deadline for notice of the settlement to be November 6, 2024
published and posted consistent with the
proposed notice plan
Filing deadline for motions for attorneys’ fees December 6, 2024
and expenses
Filing deadline for shareholders’ objections to January 13, 2025
the settlement
Filing deadline for the parties’ replies to January 27, 2025
shareholder settlement objections
Filing deadline for responses to motions for December 13, 2024
attorneys’ fees and expenses
Filing deadline for replies to motions for December 20, 2024
attorneys’ fees and expenses

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Filing deadline for shareholders’ objections to January 13, 2025
motions for attorneys’ fees and expenses
Filing deadline for the final approval motion

December 6, 2024

Final approval settlement hearing

February 6, 2025

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-2STIPULATION AND ORDER AS TO DATES FOR MOTIONS FOR FINAL
SETTLEMENT APPROVAL AND ATTORNEYS’ FEES

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Dated: October 23, 2024

Respectfully submitted,
By: /s/Gregory M. Nespole
LEVI & KORSINSKY, LLP
Gregory M. Nespole (pro hac vice)
33 Whitehall Street, 17th Floor
New York, NY 10004
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Adam Apton
1160 Battery Street East Suite 100 - #3425
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
THE BROWN LAW FIRM, P.C.
Robert C. Moest, Of Counsel, SBN 62166
2530 Wilshire Boulevard, Second Floor
Santa Monica, California 90403
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Timothy Brown (pro hac vice)
240 Townsend Square
Oyster Bay, NY 11771
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Co-lead Counsel for Plaintiffs
By: /s/Andrew B. Clubok
LATHAM & WATKINS LLP
Andrew B. Clubok (pro hac vice)
555 Eleventh Street, NW, Suite 1000
Washington, D.C. 20004
T: [phone] / F: [phone]
[e-mail]
Matthew Rawlinson (SBN 231890)
140 Scott Drive
Menlo Park, California 94025
T: [phone] / F: [phone]
[e-mail]
[signatures continued on next page]

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-3STIPULATION AND ORDER AS TO DATES FOR MOTIONS FOR FINAL
SETTLEMENT APPROVAL AND ATTORNEYS’ FEES

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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 Nominal Defendant Lyft, Inc. and
Defendants 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

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ECF ATTESTATION

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Pursuant to Civil L.R. 5-1(i)(3), the filer attests that concurrence in the filing of this document

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Executed this 23rd day of October in New Rochelle, New York.

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By: /s/ Gregory M. Nespole
Gregory M. Nespole

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
Date: 10/24/2024

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

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-4STIPULATION AND ORDER AS TO DATES FOR MOTIONS FOR FINAL
SETTLEMENT APPROVAL AND ATTORNEYS’ FEES