STIPULATION AND [PROPOSED] ORDER REGARDING TIME TO FILE CONSOLIDATED CLASS ACTION COMPLAINT AND SETTING BRIEFING SCHEDULE
VINCE CHHABRIA, District Judge.
WHEREAS, on July 23, 2014, counsel for defendants and counsel for certain plaintiffs that filed the initial complaints in the now-consolidated, above-referenced action filed a stipulation (the "Prior Stipulation") that set the time for (1) filing an amended consolidated complaint within forty-five (45) days from the date the Court appointed lead plaintiffs; and (2) defendants to file a motion to dismiss, answer, or other response to the amended consolidated complaint within forty-five (45) days from the date the complaint was filed [Dkt. #13];
WHEREAS, on July 25, 2014, the Court granted the Prior Stipulation [Dkt. #14];
WHEREAS, on September 26, 2014, the Honorable Vince Chhabria issued an Order appointing State-Boston Retirement System, Arkansas Teacher Retirement System, and Oklahoma Police Pension & Retirement System (together, the "Retirement Systems") as Lead Plaintiff, and approved Lead Plaintiff's selection of Labaton Sucharow LLP as Lead Counsel for the Class, and Lieff, Cabraser, Heimann & Bernstein, LLP as Liaison Counsel for the Class [Dkt. #43];
WHEREAS, Lead Counsel and Lead Plaintiff were not involved in the Prior Stipulation and wished to confer with defendants regarding a revised schedule;
WHEREAS, Lead Plaintiff and defendants Infoblox, Inc., Remo E. Canessa, and Robert D. Thomas (collectively, "Defendants"), through their respective counsel, have conferred and agreed upon the time for Lead Plaintiff to file a Consolidated Class Action Complaint (the "Complaint"); and
WHEREAS, Lead Plaintiff and Defendants, through their respective counsel, have further agreed upon the time for Defendants to answer, move to dismiss, or otherwise respond to the Complaint, and the schedule for briefing any such motion to dismiss;
IT IS HEREBY STIPULATED and agreed, by the parties, through their undersigned counsel, subject to Court approval, as follows:
1. Lead Plaintiff shall file its Consolidated Complaint on or before November 25, 2014.
2. Defendants will answer, move, or otherwise respond to the Complaint on or before January 26, 2015.
3. In the event Defendants move to dismiss the complaint, any opposition thereto shall be filed on or before March 27, 2015; Defendants' reply in further support of their motion to dismiss shall be filed on or before April 27, 2015; and the Court will hear the motion on May 14, 2015.
4. The foregoing schedule may be modified by agreement of the parties with approval of the Court.
5. The foregoing schedule supersedes any other schedules previously set in the action or provided in the Local Rules of the Court.
Pursuant to L.R. 5-1(i)(3), all signatories concur in filing this stipulation.
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT:
1. Lead Plaintiff shall file its Consolidated Complaint on or before November 25, 2014.
2. Defendants will answer, move, or otherwise respond to the Complaint on or before January 26, 2015.
3. In the event Defendants move to dismiss the complaint, any opposition thereto shall be filed on or before March 27, 2015; Defendants' reply in further support of their motion to dismiss shall be filed on or before April 27, 2015; and the Court will hear the motion on May 14, 2015.
4. The foregoing schedule may be modified by agreement of the parties with approval of the Court.
5. The foregoing schedule supersedes any other schedules previously set in the action or provided in the Local Rules of the Court.
