Vitalone v. Logitech International SA et al
Filing
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STIPULATION AND ORDER 47 Regarding Deadlines for Filing Amended Complaint and Briefing in Response Thereto. Signed by Judge Richard Seeborg on 8/9/12. (cl, COURT STAFF) (Filed on 8/9/2012)
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ROBBINS GELLER RUDMAN
& DOWD LLP
DENNIS J. HERMAN (220163)
Post Montgomery Center
One Montgomery Street, Suite 1800
San Francisco, CA 94104
Telephone: 415/288-4545
415/288-4534 (fax)
dherman@rgrdlaw.com
— and —
ASHLEY M. PRICE (281797)
655 West Broadway, Suite 1900
San Diego, CA 92101
Telephone: 619/231-1058
619/231-7423 (fax)
aprice@rgrdlaw.com
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Lead Counsel for Plaintiffs
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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CARL VITALONE, Individually and on
Behalf of All Others Similarly Situated,
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Plaintiff,
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vs.
LOGITECH INTERNATIONAL SA, et al.,
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Defendants.
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7475451
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No. 3:11-cv-03855-RS
CLASS ACTION
STIPULATION AND [PROPOSED] ORDER
REGARDING DEADLINES FOR FILING
AMENDED COMPLAINT AND BRIEFING
IN RESPONSE THERETO
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Lead Plaintiff Sing Pui Leung ("Leung") and Defendants Logitech Intenrational, S.A.,
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Gerald P. Quindlen and Erik Bardman ("Defendants"), pursuant to Civil L.R. 6-2, hereby jointly
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seek entry of the following proposed schedule extending the deadline for filing an amended
4 complaint in this action to and including August 28, 2012 and establishing deadlines for responding
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thereto, and as grounds therefor state as follows:
1.
On July 13, 2012, the Court granted defendants' motion to dismiss the Consolidated
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Class Action Complaint (Dkt. No. 45). The Order provides that Lead Plaintiff may ifle an amended
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complaint on or before August 13, 2012.
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2.
Lead Plaintiff has worked diligently to amend his complaint within the time required
10 by the Coutr, but is not yet in a position to amend the complaint in the manner necessary to respond
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to all of the issues raised by the Court in its Order, in patr due to travel plans and other commitments
12 that have limited the availability of some potential witnesses sought to be interviewed in connection
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with Lead Plaintiff's continuing investigation of the claims asserted in this proceeding.
3.
Accordingly, Lead Plaintiff has requested that defendants consent to an additional
15 period of time to prepare an amended complaint. Defendants have agreed to a 15 day extension of
16 the deadline for filing an amended complaint, to and including August 28, 2012.
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4.
Defendants have also proposed, and plaintiffs have agreed to, the following deadlines
for defendants to respond to the amended complaint and, if the response is by way of a Rule 12
19 motion, for submitting response and reply briefs thereto:
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Defendants' Motion to Dismiss:
Lead Plaintiff's Opposition to the Motion to Dismiss:
Defendants' Reply in Support of the Motion to Dismiss:
October 1, 2012
October 31, 2012
November 15, 2012
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THEREFORE, it is hereby stipulated and agreed by the patries, subject to the approval of the
24 Coutr, that the parties shall follow the schedule as amended above.
DATED: August 9, 2012
ROBBINS GELLER RUDMAN
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& DOWD LLP
DENNIS J. HERMAN
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7475451
s/ Dennis J. Hermna
DENNIS J. HERMAN
STIPULATION AND [PROPOSED] ORDER REGARDING DEADLINES FOR FILING AMENDED
COMPLAINT AND BRIEFING IN RESPONSE THERETO - 3:11-cv-03855-RS
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Post Montgomery Center
One Montgomery Street, Suite 1800
San Francisco, CA 94104
Telephone: 415/288-4545
415/288-4534 (fax)
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ROBBINS GELLER RUDMAN
& DOWD LLP
ASHLEY M. PRICE
655 West Broadway, Suite 1900
San Diego, CA 92101
Telephone: 619/231-1058
619/231-7423 (fax)
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Lead Counsel for Plaintiffs
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DATED: August 9, 2012
WILSON SONSINI GOODRICH & ROSATI PC
IGNACIO E. SALCEDA
DIANE M. WALTERS
BENJAMIN M. CROSSON
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s/ Ignacio E. Salcedo (w/ permission)
IGNACIO E. SALCEDA
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650 Page Mill Road
Palo Alto, CA 94304-1050
Telephone: 650/493 -93 00
650/565-5100 (fax)
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Attonreys for Defendants Logitech Intenrational
S.A., Gerald P. Quindlen and Erik Bardman
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Certificate Pursuant to Local Rule 5-1(i)(3)
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I, Dennis J. Herman, am the ECF User whose identification and password are being used to
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file the Stipulation and [Proposed] Order Regarding Deadlines for Filing Amended Complaint and
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Brieifng in Response Thereto. In compliance with Local Rule 5-1(i)(3), I hereby attest that Ignacio
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E. Salceda has concurred in this ifling.
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Dated: August 9, 2012
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s/ Dennis J. Hermna
DENNIS J. HERMAN
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7475451
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STIPULATION AND [PROPOSED] ORDER REGARDING DEADLINES FOR FILING AMENDED
COMPLAINT AND BRIEFING IN RESPONSE THERETO - 3:11-cv-03855-RS
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ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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8/9/12
THE HONORABLE RICHARD SEEBORG
UNITED STATES DISTRICT JUDGE
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7475451
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STIPULATION AND [PROPOSED] ORDER REGARDING DEADLINES FOR FILING AMENDED
COMPLAINT AND BRIEFING IN RESPONSE THERETO - 3:11-cv-03855-RS
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