IN RE:JUNIPER SECURITIES LITIGATION

Filing 450

STIPULATION AND ORDER 440 re Juniper Networks, Inc.'s Fifth Set of Interrogatories (Nos. 16-32). Signed by Judge Patricia V. Trumbull on 12/8/09. (pvtlc1) (Filed on 12/8/2009)

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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

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 JUNIPER NETWORKS, INC.'S FIFTH SET OF INTERROGATORIES (NOS. 16-32) BEFORE: Hon. Patricia V. Trumbull

This Document Relates To: All Actions

STIPULATION AND [PROPOSED] ORDER RE JUNIPER NETWORKS, INC.'S FIFTH SET OF INTERROGATORIES (NOS. 16-32) 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. ("Juniper"), by and through their respective attorneys of record. WHEREAS, on November 13, 2009, Lead Plaintiff served its Responses and Objections to Juniper's Fifth Set of Interrogatories (Nos. 16-32) ("Fifth Set of Interrogatories"); WHEREAS, the parties met and conferred on November 20, 2009, and Lead Plaintiff agreed to serve amended responses to Juniper's Fifth Set of Interrogatories on or before December 31, 2009; WHEREAS, pursuant to the same meet and confer, the parties agreed that if Juniper believes Lead Plaintiff's amended responses are still deficient, and the parties cannot resolve the dispute through further meet and confers, Juniper may file and serve a motion to compel further responses to its Fifth Set of Interrogatories 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 Plaintiffs' responses to Juniper's Fifth Set of Interrogatories that cannot be resolved through meet and confers, Juniper may file and serve a motion to compel further responses to the Fifth 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 1, 2009 WILSON SONSINI GOODRICH & ROSATI By: /s/ Joni Ostler Joni Ostler

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STIP AND [PROPOSED] ORDER RE JUNIPER'S 5TH & 6TH SETS OF INTERROGS. & 2ND REQUESTS FOR ADMISSION CASE NO. C06-04327-JW (PVT)

Counsel for Juniper Networks, Inc.

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Dated: December 1, 2009

LOWEY DANNENBERG COHEN & HART, P.C. By: /s/ David Harrison David Harrison

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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'S 5TH & 6TH SETS OF INTERROGS. & 2ND REQUESTS FOR ADMISSION CASE NO. C06-04327-JW (PVT)

12/8/09 PATRICIA V. TRUMBULL United States Magistrate Judge

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