Case 4:19-cv-02033-YGR Document 243 Filed 04/29/22 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
`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
`SUPPLEMENTAL MOTION FOR CLASS
`CERTIFICATION
`
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`STIPULATION AND [PROPOSED] ORDER RE BRIEFING
`SCHEDULE FOR LEAD PLT’S SUPPLEMENTAL MOTION FOR
`CLASS CERTIFICATION, CASE NO. 19-CV-02033-YGR
`
`

`

`Case 4:19-cv-02033-YGR Document 243 Filed 04/29/22 Page 2 of 4
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`This Stipulation is entered into by and among Lead Plaintiff Norfolk County Council as
`Administering Authority of the Norfolk Pension Fund (“Lead Plaintiff”) and Defendants Apple
`Inc. (“Apple”), Timothy Cook, and Luca Maestri (collectively “Defendants” and together with the
`Lead Plaintiff, the “Parties”), through their respective attorneys of record.
`WHEREAS, on May 5, 2021, Lead Plaintiff filed a Motion for Class Certification (the
`“Motion”) [Dkt. No. 165];
`WHEREAS, on February 4, 2022, the Court issued an order granting in part and denying
`in part the Motion (the “Order”) [Dkt. No. 224]. The Order denied without prejudice Lead
`Plaintiff’s Motion with respect to holders of options on Apple stock and contemplated that Lead
`Plaintiff may “re-seek certification with respect to this category of investors”;
`WHEREAS, on March 4, 2022, the Court issued an order setting a deadline of April 15,
`2022 for Lead Plaintiff to supplement its class certification motion regarding holders of options
`on Apple stock [Dkt. No. 231];
`WHEREAS, on April 15, 2022, Lead Plaintiff filed a Supplemental Motion to Certify
`Class of Apple Options Investors (the “Supplemental Motion”) [Dkt. No. 239], which attached,
`among other things, an expert report by Don Chance;
`WHEREAS, Lead Plaintiff has agreed to make Professor Chance available for deposition
`on June 8, 2022;
`WHEREAS, it is Defendants’ current intention to file an expert report in connection with
`its opposition to the Supplemental Motion;
`WHEREAS, Plaintiff anticipates that a deposition of Defendants’ expert may be
`necessary;
`WHEREAS, the Parties have met and conferred and reached an agreement to set a
`briefing schedule for the Supplemental Motion which sets forth sufficient time for all parties to
`take any expert discovery, as set forth below;
`NOW THEREFORE, it is stipulated and agreed among the undersigned Parties, and
`respectfully submitted for the Court’s approval as follows:
`1.
`Defendants shall file any opposition to the Supplemental Motion no later than June
`STIPULATION AND [PROPOSED] ORDER RE BRIEFING
`SCHEDULE FOR LEAD PLT’S SUPPLEMENTAL MOTION FOR
`CLASS CERTIFICATION, CASE NO. 19-CV-02033-YGR
`
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`Case 4:19-cv-02033-YGR Document 243 Filed 04/29/22 Page 3 of 4
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`24, 2022;
`Lead Plaintiff shall file any reply in support of the Supplemental Motion no later
`2.
`than August 26, 2022;
`IT IS SO STIPULATED.
`
`Dated: April 28, 2022
`
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
`/s/ James N. Kramer
`JAMES N. KRAMER
`Attorneys for Defendants
`Apple Inc., Timothy Cook and Luca Maestri
`
`Dated: April 28, 2022
`
`ROBBINS GELLER RUDMAN & DOWD LLP
`
`/s/ Shawn A. Williams
`SHAWN A. WILLIAMS
`Counsel 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 Supplemental 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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`STIPULATION AND [PROPOSED] ORDER RE BRIEFING
`SCHEDULE FOR LEAD PLT’S SUPPLEMENTAL MOTION FOR
`CLASS CERTIFICATION, CASE NO. 19-CV-02033-YGR
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`Case 4:19-cv-02033-YGR Document 243 Filed 04/29/22 Page 4 of 4
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`***
`PURSUANT TO STIPULATION, IT IS SO ORDERED.
`
`Dated:
`
`April 29, 2022
`
`HONORABLE YVONNE GONZALEZ ROGERS
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`- 3 -
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`STIPULATION AND [PROPOSED] ORDER RE BRIEFING
`SCHEDULE FOR LEAD PLT’S SUPPLEMENTAL MOTION FOR
`CLASS CERTIFICATION, CASE NO. 19-CV-02033-YGR
`
`