IN RE:JUNIPER SECURITIES LITIGATION

Filing 529

STIPULATION AND ORDER re 520 the Juniper Defendants' Discovery Requests. Signed by Judge Patricia V. Trumbull on 2/2/10. (pvtlc1) (Filed on 2/3/2010)

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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 ORDER RE THE JUNIPER DEFENDANTS' DISCOVERY REQUESTS BEFORE: Hon. Patricia V. Trumbull

This Document Relates To: All Actions

STIP. AND ORDER RE JUNIPER DEFENDANTS' DISCOVERY REQUESTS 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, pursuant to Stipulations and Orders dated December 7 and 8, 2009, Lead Plaintiff agreed to serve amended responses to the Juniper Defendants' Fifth Set of Interrogatories and the Juniper Defendants' Second Set of Requests for Admission and Sixth Set of Interrogatories (collectively, "Requests"), after which the parties would meet and confer if necessary, and if such further meet and confers were unsuccessful the Juniper Defendants' deadline to file and serve a motion to compel further responses to the Requests was extended to ten days from the date on which the parties reached an impasse, but in no event later than January 29, 2010; WHEREAS, Lead Plaintiff served its amended responses to the Requests on January 11,

WHEREAS, in light of the fact that the parties are scheduled to participate in a settlement mediation on February 4-5, 2010, and in the interests of efficiency, the parties have agreed that the Juniper Defendants' deadline to file and serve any motion to compel further responses to the Requests should be further extended to February 12, 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 amended responses to the Juniper Defendants' Fifth Set of Interrogatories, and 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 on or before February 12, 2010, and such motion will not be deemed untimely.

STIP. AND ORDER RE JUNIPER DEFENDANTS' DISCOVERY REQUESTS CASE NO. C06-04327-JW (PVT)

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1 2 3 Dated: January 27, 2010

Respectfully submitted, WILSON SONSINI GOODRICH & ROSATI By: /s/ Joni Ostler Joni Ostler

4 5 6 7 By: 8 9 10 * 11 12 * Dated: January 27, 2010

Counsel for the Juniper Defendants LOWEY DANNENBERG COHEN & HART, P.C. /s/ David Harrison David Harrison

Counsel for Lead Plaintiff *

ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. 13 DATED: 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
STIP. AND ORDER RE JUNIPER DEFENDANTS' DISCOVERY REQUESTS CASE NO. C06-04327-JW (PVT)

2/2/10 PATRICIA V. TRUMBULL United States Magistrate Judge

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