Filed: Feb. 21, 2017
Latest Update: Feb. 21, 2017
Summary: STIPULATION AND [ PROPOSED ] ORDER EXTENDING TIME TO RESPOND TO COMPLAINT EDWARD M. CHEN , District Judge . WHEREAS, Plaintiff Douglas Bragan ("Plaintiff") filed his Complaint for Violation of the Federal Securities Laws on December 21, 2016 ("Complaint"); WHEREAS, Defendants waived service of the Complaint, and their responses to the Complaint are currently due February 21, 2017; WHEREAS, the Court has ordered this case related to four other cases currently pending in the Northern
Summary: STIPULATION AND [ PROPOSED ] ORDER EXTENDING TIME TO RESPOND TO COMPLAINT EDWARD M. CHEN , District Judge . WHEREAS, Plaintiff Douglas Bragan ("Plaintiff") filed his Complaint for Violation of the Federal Securities Laws on December 21, 2016 ("Complaint"); WHEREAS, Defendants waived service of the Complaint, and their responses to the Complaint are currently due February 21, 2017; WHEREAS, the Court has ordered this case related to four other cases currently pending in the Northern D..
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STIPULATION AND [ PROPOSED ] ORDER EXTENDING TIME TO RESPOND TO COMPLAINT
EDWARD M. CHEN, District Judge.
WHEREAS, Plaintiff Douglas Bragan ("Plaintiff") filed his Complaint for Violation of the Federal Securities Laws on December 21, 2016 ("Complaint");
WHEREAS, Defendants waived service of the Complaint, and their responses to the Complaint are currently due February 21, 2017;
WHEREAS, the Court has ordered this case related to four other cases currently pending in the Northern District of California, entitled Steinberg v. Brocade Communications Systems, Inc., et al., Case No. 3:16-cv-07081-EMC, Gross v. Brocade Communications Systems, Inc., et al., Case No. 3:16-cv-07173-EMC, Jha v. Brocade Communications Systems, Inc., et al., Case No. 3:16-cv-07270-EMC, and Chuakay v. Brocade Communications Systems, Inc, et al., Case No. 3:17-cv-00058-EMC;
WHEREAS, counsel for Plaintiff and counsel for Defendants have stipulated that Defendants need not answer the Complaint and shall meet and confer on a schedule after consolidation of this case and the above-referenced cases and after the filing of a consolidated amended complaint;
NOW, THEREFORE, the parties, by and through their respective counsel, stipulate and agree as follows:
1. Defendants shall not be required to, and shall not waive any rights, arguments, or defenses by waiting to, answer, move, or otherwise respond to the Complaint in this action;
2. Defendants and Plaintiff shall meet and confer on a schedule after consolidation and the filing of a consolidated amended complaint;
3. Nothing in this Stipulation shall be construed as a waiver of any of Defendants' rights or positions in law or in equity, or as a waiver of any defenses that the Brocade Defendants would otherwise have, including, without limitation, jurisdictional defenses.
IT IS SO STIPULATED.
[PROPOSEDORDER
GOOD CAUSE HAVING BEEN SHOWN, it is hereby ordered that:
1. Defendants will not be required to, and shall not waive any rights, arguments, or defenses by waiting to, answer, move, or otherwise respond to the Complaint in this action;
2. Defendants and Plaintiff shall meet and confer on a schedule after consolidation and the filing of a consolidated amended complaint;
3. Nothing in this Stipulation shall be construed as a waiver of any of Defendants' rights or positions in law or in equity, or as a waiver of any defenses that Defendants would otherwise have, including, without limitation, jurisdictional defenses.
IT IS SO ORDERED.
ATTESTATION
I, Boris Feldman, am the ECF user whose ID and password are being used to file this STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND TO COMPLAINT. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that Hilary H. Mattis and Evan J. Smith have concurred in this filing.
