Filed: Apr. 06, 2018
Latest Update: Apr. 06, 2018
Summary: STIPULATION AND [PROPOSED] ORDER EDWARD M. CHEN , District Judge . WHEREAS, the above-captioned action is a proposed class action alleging violations of the federal securities laws against PayPal Holdings, Inc. ("Paypal" or the "Company"), Daniel H. Schulman ("Schulman"), John D. Rainey Jr. ("Rainey"), and Hamed Shahbazi ("Shahbazi") (collectively, "Defendants"); WHEREAS, this action is subject to the requirements of the Private Securities Litigation Reform Act of 1995, Pub. L. No. 1
Summary: STIPULATION AND [PROPOSED] ORDER EDWARD M. CHEN , District Judge . WHEREAS, the above-captioned action is a proposed class action alleging violations of the federal securities laws against PayPal Holdings, Inc. ("Paypal" or the "Company"), Daniel H. Schulman ("Schulman"), John D. Rainey Jr. ("Rainey"), and Hamed Shahbazi ("Shahbazi") (collectively, "Defendants"); WHEREAS, this action is subject to the requirements of the Private Securities Litigation Reform Act of 1995, Pub. L. No. 10..
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STIPULATION AND [PROPOSED] ORDER
EDWARD M. CHEN, District Judge.
WHEREAS, the above-captioned action is a proposed class action alleging violations of the federal securities laws against PayPal Holdings, Inc. ("Paypal" or the "Company"), Daniel H. Schulman ("Schulman"), John D. Rainey Jr. ("Rainey"), and Hamed Shahbazi ("Shahbazi") (collectively, "Defendants");
WHEREAS, this action is subject to the requirements of the Private Securities Litigation Reform Act of 1995, Pub. L. No. 104-67, 109 Stat. 737 (1995) (the "PSLRA"), which sets forth specialized procedures for the administration of securities class actions;
WHEREAS, on March 16, 2018, the Court entered an order appointing movants Michael Eckert and Edwin Bell as Interim Co-Lead Plaintiffs and approving their choices of Pomerantz LLP and The Rosen Law Firm, P.A. as Interim Co-lead Counsel (Dkt. No. 31);
WHEREAS, on March 30, 2018, the Court entered an order regarding the timing of the filing of an amended complaint and Defendants Paypal, Schulman, and Rainey's response thereto (Dkt. No.41) ("Scheduling Order");
WHEREAS, Shahbazi was not a party to the previously entered Scheduling Order and at the time of the filing of the previous stipulation, Interim Co-Lead Counsel was negotiating the issue of service of process with Shahbazi's Canadian counsel; and
WHEREAS, so that the schedule of Shahbazi's response to an amended complaint is consistent with the schedule for PayPal, Schulman, and Rainey's response;
IT IS ACCORDINGLY STIPULATED, by and between the undersigned counsel for the parties, that:
1. Pursuant to the Court's Order dated March 30, 2018 (Docket No. 41) Interim Co-Lead Plaintiffs shall file an amended complaint on or before June 12, 2018;
2. Defendant Shahbazi shall file his response to the amended complaint within thirty (30) days after the filing of the amended complaint; and
3. If Defendant Shahbazi moves to dismiss the amended complaint, Interim Co-Lead Plaintiffs' opposition shall be due within thirty (30) days after the filing of the
motion(s) to dismiss; and any replies shall be due within twenty (20) days after the filing of Interim Co-Lead Plaintiffs' opposition.
Pursuant to Civil L.R. 5-1(i)(3), all signatories concur in filing this stipulation.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
