CLASS ACTION

STIPULATION AND [PROPOSED] ORDER REQUESTING ORDER CHANGING TIME ALL ACTIONS.

JON S. TIGAR, District Judge.

Pursuant to California Civil Local Rule 6-2, the parties, Class Representatives KBC Asset Management NV ("KBC") and National Elevator Industry Pension Fund ("NEIPF") (collectively, "Plaintiffs") and defendants Twitter, Inc., Richard Costolo, and Anthony Noto (collectively, "Defendants"), by and through their undersigned counsel of record, submit the following stipulation and proposed order:

WHEREAS, on April 3, 2019, the Parties served discovery on Defendants, pursuant to Federal Rules of Civil Procedure Rules 33 and 36, respectively (Declaration of Daniel S. Drosman in Support of Stipulated Request for Order Changing Time ("Drosman Decl."), ¶2):

WHEREAS, on April 3, 2019, Defendants served the following discovery on Plaintiffs, pursuant to Federal Rules of Civil Procedure Rules 33, 34 and 36 (id.):

WHEREAS, the fact discovery deadline is May 3, 2019 (ECF No. 214);

WHEREAS, prior to the deadline to serve responses and objections to the April 3, 2019 discovery, the Parties, through their counsel, met and conferred and agreed to a reciprocal extension of 21 days for service of the responses to this discovery, such that those responses would be due on May 24, 2019 (Drosman Decl., ¶¶3-4);

WHEREAS, the Parties further agree that any disputes regarding the responses to the April 3, 2019 Discovery must be filed with this Court within 14 days following service of the discovery responses (id., ¶5);

WHEREAS, absent a Stipulation by the Parties, the responses and objections to the above April 3, 2019 discovery requests would be due on May 3, 2019, the same day as the fact discovery deadline;

WHEREAS, the Parties are attempting to resolve certain disputes pertaining to the aforementioned discovery (collectively, "April 3, 2019 Discovery") and avoid burdening the Court with such issues (id., ¶6);

WHEREAS, the Parties have taken or defended eight depositions during April 2019 and will take or defend an additional four depositions prior to the fact discovery deadline on May 3, 2019 (id., ¶8);

WHEREAS, the Parties believe that extending the deadline to respond to discovery served on April 3, 2019 to May 24, 2019 (and allowing the parties until June 7, 2019 to meet and confer and move to compel if necessary) is necessary and appropriate in light of the volume of discovery served in this matter and the numerous depositions that are scheduled before the May 3, 2019 fact discovery deadline (id., ¶8);

WHEREAS, the Parties further agree to extend the deadline for the Rule 30(b)(6) Deposition of Defendant Twitter, Inc., which is currently noticed for May 2, 2019, until May 17, 2019, to allow the Defendants adequate time to prepare their corporate designee for the deposition in light of the Court's recent order regarding Defendant Twitter, Inc.'s Motion for a Protective Order (ECF No. 280) (Drosman Decl., ¶7), and to extend the deadline for any motion to compel further testimony in the event Twitter's corporate designee is unprepared to testify to and including May 28, 2019;

WHEREAS, extending the deadline to respond to all discovery served by any party on any other party on April 3, 2019 to May 24, 2019, and extending the deadline to complete Defendant Twitter, Inc.'s Rule 30(b)(6) Deposition will not alter the date of any other event or deadline currently scheduled in this matter besides the fact discovery deadline previously set by the Court; and

WHEREAS, the Parties previously have stipulated to modify time seven times in this matter (id., ¶9).

NOW, THEREFORE, the Parties hereby jointly request the Court enter an order: (i) extending the deadline for the Rule 30(b)(6) Deposition of Defendant Twitter, Inc. to May 17, 2019; (ii) extending the time for the Parties to respond to all discovery served on April 3, 2019 to May 24, 2019; (iii) extending the deadline for Plaintiffs to move to compel additional Rule 30(b)(6) testimony, if necessary, to and including May 28, 2019; and (iv) allowing the Parties up to and including June 7, 2019 to meet and confer and move to compel if necessary on the discovery served on April 3, 2019.

IT IS SO STIPULATED.

ATTESTATION OF SIGNATURES

Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this document has been obtained from the signatory.

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ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.