In re Silicon Storage Technology, Inc. Derivative Litigation

Filing 111

STIPULATION AND ORDER TO CONTINUE MOTION TO DISMISS HEARING AND CASE MANAGEMENT CONFERENCE (approving 110 ). Case Management Conference set for 4/24/2009 09:00 AM. Motion Hearing set for 4/24/2009 09:00 AM in Courtroom 3, 5th Floor, San Jose. Signed by Judge Jeremy Fogel on 3/9/09. (jflc2, COURT STAFF) (Filed on 3/9/2009)

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**E-Filed 3/9/09** FRANCIS M. GREGOREK (144785) [e-mail] BETSY C. MANIFOLD (182450) [e-mail] RACHELE R. RICKERT (190634) [e-mail] WOLF HALDENSTEIN ADLER FREEMAN & HERZ LLP Symphony Tower 750 B Street, Suite 2770 San Diego, CA 92101 Telephone: [phone] Facsimile: [phone] BARROWAY TOPAZ KESSLER MELTZER & CHECK, LLP NICHOLE BROWNING (251937) [e-mail] 2125 Oak Grove Road, Suite 120 Walnut Creek, CA 94598 Telephone: [phone] Facsimile: [phone] Attorneys for Lead Plaintiffs [Additional Counsel Appear On Signature Page]

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA In re SILICON STORAGE TECHNOLOGY, INC., DERIVATIVE LITIGATION Master File No. C 06-04310 JF STIPULATION AND -----------------[PROPOSED] ORDER TO CONTINUE MOTION TO DISMISS HEARING AND CASE MANAGEMENT CONFERENCE Trial Date: None

_____________________________________ This Document Relates To: ALL ACTIONS.

STIPULATION AND [PROPOSED] ORDER TO CONTINUE MOTION TO DISMISS HEARING AND CASE MANAGEMENT CONFERENCE MASTER FILE NO. C 06-04310 JF

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WHEREAS, the hearing on Defendants' Motions to Dismiss and a Case Management Conference are currently scheduled for March 13, 2009; WHEREAS, due to scheduling conflicts, the current settlement discussions, and the Parties' focus thereon, Lead Plaintiffs have requested and Defendants have consented to continue the hearing on Defendants' Motions to Dismiss and the Case Management Conference to a later date; WHEREAS, the Parties understand that April 24, 2009 is available on the Court's calendar; WHEREAS, subject to the Court's approval, the parties stipulate as follows: 1) The hearing on Defendants' Motions to Dismiss currently scheduled for March 13,

2009 shall be rescheduled to April 24, 2009. 2) The Case Management Conference currently scheduled for March 13, 2009 shall be

rescheduled to April 24, 2009. 3) By executing this Stipulation, the parties have not waived and expressly retain all

claims, defenses and arguments whether procedural, substantive or otherwise. This Stipulation is without prejudice to any subsequent motion to stay this action, or any objections or defenses thereto, and this Order is entered without prejudice to the rights of any party to apply for a modification of this Order. IT IS SO STIPULATED. DATED: March 6, 2009 Respectfully Submitted, BARROWAY TOPAZ KESSLER MELTZER & CHECK, LLP ______/s/______________________________ NICHOLE BROWNING (251937) 2125 Oak Grove Road, Suite 120 Walnut Creek, CA 94598 Telephone: [phone] Facsimile: [phone] ERIC L. ZAGAR JAMES H. MILLER 280 King of Prussia Road Radnor, PA 19087 Telephone: [phone] Facsimile: [phone]
STIPULATION AND [PROPOSED] ORDER TO CONTINUE MOTION TO DISMISS HEARING AND CASE MANAGEMENT CONFERENCE MASTER FILE NO. C 06-04310 JF -1-

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: March 6, 2009 DATED: March 6, 2009 DATED: March 6, 2009

WOLF HALDENSTEIN ADLER FREEMAN & HERZ LLP FRANCIS M. GREGOREK BETSY C. MANIFOLD RACHELE R. RICKERT Symphony Towers 750 B Street, Suite 2770 San Diego, CA 92101 Telephone: [phone] Facsimile: [phone] Attorneys for Lead Plaintiffs COOLEY GODWARD LLP AARON OLSEN ____/s/_______________________________ WILLIAM FREEMAN JOHN DWYER AARON OLSEN Five Palo Alto Square 3000 El Camino Real Palo Alto, CA 94306-2155 Telephones: 650-843-5000 Facsimile: 650-857-0663 Attorneys for Nominal Defendant, Silicon Storage Technology, Inc. MCDERMOTT, WILL & EMERY LLP _____/s/_____________________________ MATTHEW J. JACOBS Attorneys for Director Defendants HOGAN & HARTSON LLP ____/s/_______________________________ HOWARD S. CARO Attorneys for Officer Defendants

STIPULATION AND [PROPOSED] ORDER TO CONTINUE MOTION TO DISMISS HEARING AND CASE MANAGEMENT CONFERENCE MASTER FILE NO. C 06-04310 JF

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ATTESTATION PURSUANT TO GENERAL ORDER 45 I, Nichole T. Browning, attest that concurrence in the filing of this document has been obtained from the other signatory. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 6th day of March, 2009, at Walnut Creek, California. /s/ * * ORDER PURSUANT TO STIPULATION AND FOR GOOD CAUSE SHOWN HEREIN, IT IS SO ORDERED. 3/9/09 Judge of the U.S. District Court Honorable Jeremy Fogel

Nichole Browning *

STIPULATION AND [PROPOSED] ORDER TO CONTINUE MOTION TO DISMISS HEARING AND CASE MANAGEMENT CONFERENCE MASTER FILE NO. C 06-04310 JF

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