City of Royal Oak Retirement System v. Juniper Networks, Inc. et al

Filing 98

Order by Hon. Lucy H. Koh granting 97 Stipulation to Extend Briefing Schedule.(lhklc3, COURT STAFF) (Filed on 10/12/2012)

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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4 CITY OF OMAHA POLICE AND FIRE
RETIREMENT SYSTEM and CITY OF
5 BRISTOL PENSION FUND, Individually and on
Behalf of All Others Similarly Situated,
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Plaintiff,
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No.: 5:11-cv-04003-LHK

Before: Hon. Lucy H. Koh

vs.
JUNIPER NETWORKS, INC., SCOTT G.
9 KRIENS, KEVIN R. JOHNSON and ROBYN
M. DENHOLM,
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Defendants.
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STIPULATION AND [Proposed] ORDER

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Pursuant to Local Rule 6-2, the parties to the above-captioned action hereby stipulate to

14 extend the briefing schedule for Defendants’ motion to dismiss by one week. The current
15 briefing schedule is as follows:
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Plaintiffs’ Brief in Opposition: October 15, 2012
Defendants’ Replies: November 1, 2012
The parties respectfully propose the following briefing schedule:

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Plaintiffs’ Brief in Opposition: October 22, 2012

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Defendants’ Replies: November 8, 2012

22 SO STIPULATED
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/s/ Thomas L. Laughlin IV
Thomas L. Laughlin IV
SCOTT+SCOTT LLP
The Chrysler Building
405 Lexington Avenue, 40th Floor
New York, NY 10174
Telephone: [phone]
Facsimile: 212-223-6334
Email: [e-mail]
Attorney for Plaintiffs
No. 5:11-cv-04003-LHK

/s/ Joni Ostler
Joni Ostler, State Bar No. 230009
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
650 Page Mill Road
Palo Alto, CA 94304-1050
Telephone: [phone]
Facsimile: 650-565-5100
Email: [e-mail]

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Attorney for Defendants

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Pursuant to Local Rule 6-2, this stipulation is supported by the following Declaration of

9 Thomas Laughlin.
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DECLARATION OF THOMAS LAUGHLIN
I, Thomas Laughlin, declare:
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I am an attorney at Scott+Scott LLP, counsel for Plaintiffs in this action. I have

the principal responsibility for preparing Plaintiffs’ brief in opposition to Defendants’ motion to

15 dismiss. I make this declaration in support of the parties’ stipulation to extend the briefing
16 schedule for Defendants’ motion to dismiss by one week.
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2.

This is the first request for an extension of time of the briefing schedule for

18 Defendants’ motion to dismiss.
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3.

The parties have stipulated to this extension at my request. Although I have acted

with due diligence, several other matters have required my immediate attention in recent weeks,
including ongoing discovery in a case in the Eastern District of Michigan, ongoing discovery in a

23 case in the District of Maine and an unexpected motion in a case pending in the Southern District
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4.

The hearing on Defendants’ motion to dismiss is scheduled for January 31, 2013.

Therefore, it does not appear that the requested extension will impact the schedule in this case.

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No. 5:11-cv-04003-LHK

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I declare under penalty of perjury that the foregoing is true and correct. Executed on October

2 11, 2012 at New York, New York.
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/s/ Thomas L. Laughlin IV
Thomas L. Laughlin IV

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SO ORDERED:
DATE: ________________
October 12, 2012

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____________________________________
Hon. Lucy H. Koh
United States District Judge

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CERTIFICATE OF SERVICE

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I, Thomas Laughlin, am the ECF user whose identification and password are being used

15 to file the foregoing Stipulation and [Proposed] Order. In compliance with General Order
16 45.X.B, I hereby attest that Joni Ostler has concurred in this filing.
17 Dated: October 11, 2012
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/s/ Thomas L. Laughlin IV
Thomas L. Laughlin IV
SCOTT+SCOTT LLP
The Chrysler Building
405 Lexington Avenue, 40th Floor
New York, NY 10174
Telephone: [phone]
Facsimile: 212-223-6334
Email: [e-mail]
Attorney for Plaintiffs

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No. 5:11-cv-04003-LHK