Case 4:19-cv-02033-YGR Document 192 Filed 06/11/21 Page 1 of 4
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`JAMES N. KRAMER (SBN 154709)
`jkramer@orrick.com
`ALEXANDER K. TALARIDES (SBN 268068)
`atalarides@orrick.com
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`The Orrick Building
`405 Howard Street
`San Francisco, CA 94105-2669
`Telephone:
`(415) 773-5700
`Facsimile:
`(415) 773-5759
`Attorneys for Defendants Apple Inc.,
`Timothy Cook and Luca Maestri
`[additional counsel appears on signature page]
`
`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
`
`OAKLAND DIVISION
`
`IN RE APPLE INC. SECURITIES
`LITIGATION
`
`This Document Relates to:
`ALL ACTIONS.
`
`Case No. 4:19-cv-02033-YGR
`CLASS ACTION
`STIPULATION AND [PROPOSED]
`ORDER REGARDING BRIEFING
`SCHEDULE FOR LEAD PLAINTIFF’S
`MOTION FOR CLASS CERTIFICATION
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`STIPULATION AND [PROPOSED] ORDER RE BRIEFING
`SCHEDULE FOR LEAD PLAINTIFF’S MOTION FOR
`CLASS CERTIFICATION, CASE NO. 19-CV-02033-YGR
`
`

`

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`This Stipulation is entered into by and among lead plaintiff, the Norfolk County Council
`as Administering Authority of the Norfolk Pension Fund (“Norfolk” or “Lead Plaintiff”) and
`defendants Apple Inc., Timothy Cook, and Luca Maestri (collectively “Defendants”), through
`their respective attorneys of record.
`WHEREAS, on December 22, 2020, the Court entered a Case Management Order which
`established deadlines for key events in the litigation including a briefing schedule for Lead
`Plaintiff’s Motion for Class Certification (the “Motion”) [Dkt. 128];
`WHEREAS, on May 5, 2021 pursuant the December 22, 2020 Case Management Order
`Lead Plaintiff filed the Motion, which requests among other things, that Norfolk be appointed
`class representative [Dkt. 165];
`WHEREAS, pursuant to the Case Management Order, Defendants are currently scheduled
`to file their opposition to the Motion on June 30, 2021; and Lead Plaintiff’s reply in support of the
`Motion is currently due on August 13, 2021;
`WHEREAS, on June 1, 2021, following a discovery hearing concerning the scope and
`timing of Lead Plaintiff’s document productions, Judge Spero ordered: (i) that by June 11, 2021,
`Lead Plaintiff should complete production of documents reflecting Norfolk’s transactions in
`Apple securities for six months following the end of the class period, approximately three months
`more than Lead Plaintiff had already produced, and additional responsive documents located
`through the application of agreed upon search terms; and (ii) the parties to “meet and confer on a
`date for the class representative depositions and opposition to class certification” [Dkt. 176];
`WHEREAS, Lead Plaintiff has agreed to make a deponent available for a deposition
`pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure on June 22, 2021;
`WHEREAS, Defendants have proposed an adjustment to the briefing scheduled for the
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`Motion to enable Defendants to prepare their opposition to the Motion;
`NOW THEREFORE, the parties have met and conferred and agreed subject to the
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`approval of the court, to extend the briefing schedule for the Motion as follows: the deadline for
`Defendants’ opposition to the Motion will be extended from June 30, 2021 to July 9, 2021, and
`the deadline for Lead Plaintiff’s reply in support of the Motion will be extended from August 13,
`STIPULATION AND [PROPOSED] ORDER RE BRIEFING
`SCHEDULE FOR LEAD PLAINTIFF’S MOTION FOR
`CLASS CERTIFICATION, CASE NO. 19-CV-02033-YGR
`
`- 1 -
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`

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`Case 4:19-cv-02033-YGR Document 192 Filed 06/11/21 Page 3 of 4
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`2021 to August 24, 2021.
`IT IS SO STIPULATED.
```
`
`Dated: June 9, 2021
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`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
` /s/ James N. Kramer
`JAMES N. KRAMER
`Attorneys for Defendants
`Apple Inc., Timothy Cook and Luca Maestri
`
`Dated: June 9, 2021
`
`ROBBINS GELLER RUDMAN & DOWD LLP
`
` /s/ Shawn A. Williams
`SHAWN A. WILLIAMS
`Attorneys for Lead Plaintiff,
`Norfolk County Council as Administering
`Authority of the Norfolk Pension Fund
`
`CIVIL L.R. 5-1 ATTESTATION
`Pursuant to Civil L.R. 5-1(i)(3), I, James N. Kramer, am the ECF user whose ID
`and password are being used to file this Stipulation and [Proposed] Order regarding Briefing
`Schedule for Lead Plaintiff’s Motion for Class Certification. In compliance with General Order
`45, X.B., I hereby attest that Shawn A. Williams has concurred in this filing.
`
`/s/ James N. Kramer
`JAMES N. KRAMER
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`- 2 -
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`STIPULATION AND [PROPOSED] ORDER RE BRIEFING
`SCHEDULE FOR LEAD PLAINTIFF’S MOTION FOR
`CLASS CERTIFICATION, CASE NO. 19-CV-02033-YGR
`
`

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`Case 4:19-cv-02033-YGR Document 192 Filed 06/11/21 Page 4 of 4
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`***
`PURSUANT TO STIPULATION, IT IS SO ORDERED.
```
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`Dated:
`
`6/11/2021
`
`HONORABLE YVONNE GONZALEZ ROGERS
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`- 3 -
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`STIPULATION AND [PROPOSED] ORDER RE BRIEFING
`SCHEDULE FOR LEAD PLAINTIFF’S MOTION FOR
`CLASS CERTIFICATION, CASE NO. 19-CV-02033-YGR
`
`