Filed: May 15, 2019
Latest Update: May 15, 2019
Summary: CLASS ACTION STIPULATION AND ORDER TO EXTEND TIME TO REACH AGREEMENT ON SCHEDULE FOR FILING OF THE CONSOLIDATED AMENDED COMPLAINT AND ANSWER OR OTHER RESPONSE TO THE CONSOLIDATED AMENDED COMPLAINT JUDGE HAYWOOD S. GILLIAM, JR. , District Judge . This Stipulation is entered into by and between Lead Plaintiffs E. hman J:Or Fonder AB (" hman Fonder") (" hman Fonder") and Stichting Pensionenfonds PGB ("PGB," and with hman Fonder, "Lead Plaintiffs") and Defendants NVIDIA Corporation ("NVIDIA
Summary: CLASS ACTION STIPULATION AND ORDER TO EXTEND TIME TO REACH AGREEMENT ON SCHEDULE FOR FILING OF THE CONSOLIDATED AMENDED COMPLAINT AND ANSWER OR OTHER RESPONSE TO THE CONSOLIDATED AMENDED COMPLAINT JUDGE HAYWOOD S. GILLIAM, JR. , District Judge . This Stipulation is entered into by and between Lead Plaintiffs E. hman J:Or Fonder AB (" hman Fonder") (" hman Fonder") and Stichting Pensionenfonds PGB ("PGB," and with hman Fonder, "Lead Plaintiffs") and Defendants NVIDIA Corporation ("NVIDIA"..
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CLASS ACTION
STIPULATION AND ORDER TO EXTEND TIME TO REACH AGREEMENT ON SCHEDULE FOR FILING OF THE CONSOLIDATED AMENDED COMPLAINT AND ANSWER OR OTHER RESPONSE TO THE CONSOLIDATED AMENDED COMPLAINT JUDGE
HAYWOOD S. GILLIAM, JR., District Judge.
This Stipulation is entered into by and between Lead Plaintiffs E. Öhman J:Or Fonder AB ("Öhman Fonder") ("Öhman Fonder") and Stichting Pensionenfonds PGB ("PGB," and with Öhman Fonder, "Lead Plaintiffs") and Defendants NVIDIA Corporation ("NVIDIA"), NVIDIA's President and Chief Executive Officer, Jensen Huang, and NVIDIA's Executive Vice President and Chief Financial Officer, Collette Kress (collectively, "Defendants") (together with Lead Plaintiffs, the "Parties").
WHEREAS, on May 2, 2019, the Court appointed Öhman Fonder and PGB as Lead Plaintiffs and their undersigned counsel as Lead Counsel for the putative class, and ordered that "within ten days of this order the parties shall meet and confer and submit a proposed schedule for the filing of a consolidated or amended complaint and the filing of Defendants' response thereto" (ECF No. 89);
WHEREAS, on May 3, 2019, May 7, 2019, May 8, 2019, May 9, 2019, May 10, 2019, May 12, 2019, and May 13, 2019, the Parties met and conferred regarding a schedule for Lead Plaintiffs' filing of a consolidated amended complaint and any corresponding answer or responsive motion thereto;
WHEREAS, the Defendants require additional time to obtain client approval with respect to a mutually agreeable schedule; and
WHEREAS, the Parties anticipate reaching an agreement on a schedule within the week.
THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the Parties, through their undersigned counsel, as follows:
1. The Parties will submit a stipulation and proposed order on a schedule for the filing of the consolidated amended complaint and any corresponding answer or responsive motion thereto by May 17, 2019.
May 13, 2019 COOLEY LLP
/s/John C. Dwyer
John C. Dwyer (136533)
Attorneys for Defendants
NVIDIA CORPORATION, JENSEN
HUANG, and COLETTE KRESS
May 13, 2019. Respectfully submitted,
KESSLER TOPAZ
MELTZER & CHECK, LLP
/s/Jennifer Joost
JENNIFER L. JOOST (Bar No. 296164)
(jjoost@ktmc.com)
One Sansome Street, Suite 1850
San Francisco, CA 94104
Tel: (415) 400-3000
Fax: (415) 400-3001
-and-
ANDREW ZIVITZ (pro hac vice motion pending)
(azivitz@ktmc.com)
MATTHEW MUSTOKOFF (pro hac vice motion
pending)
(mmustokoff@ktmc.com)
280 King of Prussia Road
Radnor, PA 19087
Tel: (610) 667-7706
Fax: (610) 667-7056
Counsel for Lead Plaintiff E. Öhman J:or Fonder AB
and Lead Counsel for the Class
BERNSTEIN LITOWITZ BERGER
& GROSSMANN LLP
JONATHAN D. USLANER (Bar No. 256898)
(jonathanu@blbglaw.com)
12481 High Bluff Drive, Suite 300
San Diego, CA 92130
Tel: (858) 793-0070
Fax: (858) 793-0323
-and-
JEROEN VAN KWAWEGEN (pro hac vice)
(jeroen@blbglaw.com)
AVI JOSEFSON (pro hac vice)
(avi@blbglaw.com)
MICHAEL D. BLATCHLEY (pro hac vice)
(michaelb@blbglaw.com)
1251 Avenue of the Americas
New York, NY 10020
Tel: (212) 554-1400
Fax: (212) 554-1444
Counsel for Lead Plaintiff Stichting Pensioenfonds PGB
and Lead Counsel for the Class
ROSMAN & GERMAIN LLP
DANIEL L. GERMAIN
(germain@lalawyer.com)
16311 Ventura Boulevard, Suite 1200
Encino, CA 91436
Tele: (818) 788 0877
Fax: (818) 788-0885
Liaison Counsel for Lead Plaintiffs and for the Class
ATTESTATION OF CONCURRENCE IN FILING
Pursuant to the United States District Court for the Northern District of California, Civil L.R. 5-1(i)(3), I hereby attest that the concurrence to the filing of the foregoing document has been obtained from each of the other signatories.
May 13, 2019. /s/John C. Dwyer
JOHN C. DWYER (136533)
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED that:
1. The Parties will submit a stipulation and proposed order on a schedule for the filing of the consolidated amended complaint and any corresponding answer or responsive motion thereto by May 17, 2019.
SO ORDERED.
