IN RE:JUNIPER SECURITIES LITIGATION

Filing 447

STIPULATION AND ORDER re 446 the Juniper Defendants' Second Set of Requests for Admission and Sixth Set of Interrogatories. Signed by Judge Patricia V. Trumbull on 12/7/09. (pvtlc1) (Filed on 12/7/2009)

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NINA F. LOCKER, State Bar # 123838 Email: [e-mail] STEVEN GUGGENHEIM, State Bar # 201386 Email: [e-mail] JONI OSTLER, State Bar # 230009 Email: [e-mail] WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: [phone] Facsimile: [phone] Counsel for Defendants Juniper Networks, Inc., Scott Kriens, Pradeep Sindhu, Marcel Gani, Robert M. Calderoni, Kenneth Goldman, William R. Hearst III, Stratton Sclavos, Vinod Khosla, Kenneth Levy and William R. Stensrud (the "Juniper Defendants")

JEFFREY B. RUDMAN (Pro Hac Vice) Email: [e-mail] EMILY R. SCHULMAN (Pro Hac Vice) Email: [e-mail] WILMER CUTLER PICKERING HALE and DORR LLP 60 State Street Boston, MA 02109 Telephone: [phone] Facsimile: [phone] JONATHAN A. SHAPIRO (Pro Hac Vice) WILMER CUTLER PICKERING HALE and DORR LLP Email: [e-mail] 1117 California Avenue Palo Alto, CA 94304 Telephone: [phone] Facsimile: [phone] Co-Counsel for Defendant Juniper Networks, Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION In re JUNIPER NETWORKS, INC. SECURITIES LITIGATION ) ) ) ) ) ) ) ) ) ) ) CASE NO.: C06-04327-JW (PVT) STIPULATION AND [PROPOSED] ORDER RE THE JUNIPER DEFENDANTS' SECOND SET OF REQUESTS FOR ADMISSION AND SIXTH SET OF INTERROGATORIES BEFORE: Hon. Patricia V. Trumbull

This Document Relates To: All Actions

STIP. AND [PROPOSED] ORDER RE JUNIPER NETWORKS, INC.'S 2ND SET REQUESTS FOR ADM. & 6TH SET INTERROGATORIES CASE NO. C06-04327-JW (PVT)

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This Stipulation is entered into by and among Lead Plaintiff the New York City Pension Funds and Defendant Juniper Networks, Inc., Scott Kriens, Pradeep Sindhu, Marcel Gani, Robert M. Calderoni, Kenneth Goldman, William R. Hearst III, Stratton Sclavos, Vinod Khosla, Kenneth Levy and William R. Stensrud (the "Juniper Defendants"), by and through their respective attorneys of record. WHEREAS, on November 30, 2009, Lead Plaintiff served its Responses and Objections to the Juniper Defendants' Second Set of Requests for Admission and Sixth Set of Interrogatories (collectively, "Requests"); WHEREAS, the parties met and conferred on December 2, 2009, and Lead Plaintiff agreed to serve amended responses to the Requests on or before January 11, 2010; WHEREAS, pursuant to the same meet and confer, the parties also agreed that if the Juniper Defendants believe Lead Plaintiff's amended responses are still deficient, and the parties cannot resolve the dispute through further meet and confers, the Juniper Defendants may file and serve a motion to compel further responses to the Requests within ten days from the date on which the parties reach an impasse, but in no event later than January 29, 2010. THEREFORE, the parties stipulate, and request that the Court order, as follows: If the parties have disputes regarding the sufficiency of Lead Plaintiff's responses to the Juniper Defendants' Second Set of Requests for Admission and Sixth Set of Interrogatories that cannot be resolved through meet and confers, the Juniper Defendants may file and serve a motion to compel further responses to the Second Set of Requests for Admission and Sixth Set of Interrogatories within ten days from the date on which the parties reach an impasses, but in no event later than January 29, 2010, and such motion will not be deemed untimely. Respectfully submitted, Dated: December 3, 2009 WILSON SONSINI GOODRICH & ROSATI By: /s/ Joni Ostler Joni Ostler

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STIP. AND [PROPOSED] ORDER RE JUNIPER NETWORKS, INC.'S 2ND SET REQUESTS FOR ADM. & 6TH SET INTERROGATORIES CASE NO. C06-04327-JW (PVT)

Counsel for the Juniper Defendants

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Dated: December 3, 2009

LOWEY DANNENBERG COHEN & HART, P.C. By: /s/ Deborah Rogozinski Deborah Rogozinski

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Counsel for Lead Plaintiff *

ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. 8 DATED: 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
STIP. AND [PROPOSED] ORDER RE JUNIPER NETWORKS, INC.'S 2ND SET REQUESTS FOR ADM. & 6TH SET INTERROGATORIES CASE NO. C06-04327-JW (PVT)

12/7/09 PATRICIA V. TRUMBULL United States Magistrate Judge

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