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`Case 4:19-cv-02033-YGR Document 245 Filed 06/06/22 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
`(415) 773-5759
`Facsimile:
`
`
`Attorneys for Defendants Apple Inc.,
`Timothy Cook, and Luca Maestri
`
`[additional counsel appears on signature page]
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`OAKLAND DIVISION
`
`IN RE APPLE INC. SECURITIES
`LITIGATION
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`
`This Document Relates to:
`
`ALL ACTIONS.
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`Case No. 4:19-cv-02033-YGR
`CLASS ACTION
`
`STIPULATION AND [PROPOSED]
`ORDER REGARDING SCHEDULE FOR
`FURTHER BRIEFING ON LEAD
`PLAINTIFF’S MOTION TO COMPEL
`PRODUCTION OF DOCUMENTS
`WITHHELD AS PRIVILEGED
`Hon. Joseph C. Spero
`
`
`STIPULATION AND [PROPOSED] ORDER RE: SCHEDULE
`FOR FURTHER BRIEFING ON MOTION TO COMPEL
`CASE NO. 19-CV-02033-YGR
`
`

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`Case 4:19-cv-02033-YGR Document 245 Filed 06/06/22 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 April 15, 2022, the Court held a hearing on Lead Plaintiff’s Motion to
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`Compel Production of Documents Withheld as Privileged (the “Motion,” Dkt. No. 232-3);
`WHEREAS, at that hearing, and in a subsequently-issued Minute Order (Dkt. No. 238), the
`Court directed that by May 13, 2022, Defendants were to provide Lead Plaintiff with documents
`and declarations concerning the documents at issue in the Motion, and further directed the Parties
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`to engage in additional meet and confer efforts in an effort to resolve the Parties’ disputes as to
`these documents;
`WHEREAS, the Court set a schedule for further briefing in the event that the Parties were
`unable to resolve their disputes through the meet and confer process, with Lead Plaintiff’s
`supplemental brief to be filed by June 3, 2022, and Defendants’ supplemental brief to be filed by
`June 15, 2022;
`WHEREAS, the Court indicated at the hearing on the Motion that the Parties could seek an
`extension of this briefing schedule if the Parties sought additional time to meet and confer;
`WHEREAS, following Defendants’ production of certain documents and declarations on
`May 13, 2022, the Parties met and conferred concerning the scope of the production and the status
`of the dispute between the Parties following the production, as well as the potential production of
`additional documents and information by Defendants, by engaging in two extended telephonic
`discussions;
`WHEREAS, following those meet and confer efforts, Defendants have agreed to produce
`documents and information in addition to those produced on May 13, 2022, in an effort to
`facilitate further discussions regarding a potential resolution of any remaining disputes;
`WHEREAS, the Parties have conferred and agree that a brief extension of the deadlines for
`further briefing would be appropriate to allow Lead Plaintiff time to review the additional
`documents that Defendants intend to produce, and to allow the Parties additional time to determine
`
`STIPULATION AND [PROPOSED] ORDER RE: SCHEDULE
`FOR FURTHER BRIEFING ON MOTION TO COMPEL
`CASE NO. 19-CV-02033-YGR
`
`- 1 -
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`Case 4:19-cv-02033-YGR Document 245 Filed 06/06/22 Page 3 of 4
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`whether they are able to resolve, or at least narrow, their disputes as to the documents at issue in
`the Motion;
` NOW THEREFORE, it is stipulated and agreed among the undersigned Parties, and
`respectfully submitted for the Court’s approval as follows:
`1.
`By June 16, 2022, Defendants shall complete any production of additional
`documents and information that Defendants determine to provide as a result of the Parties’ recent
`meet and confer efforts;
`2.
`Lead Plaintiff shall file any supplemental brief in support of the Motion no later
`than June 22, 2022;
`3.
`Defendants shall file any response no later than July 5, 2022.
`
`IT IS SO STIPULATED.
`
`Dated: June 3, 2022
`
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
` /s/ James N. Kramer
`JAMES N. KRAMER
`Attorneys for Defendants
`Apple Inc., Timothy Cook, and Luca Maestri
`
`
`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
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`- 2 -
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`STIPULATION AND [PROPOSED] ORDER RE: SCHEDULE
`FOR FURTHER BRIEFING ON MOTION TO COMPEL
`CASE NO. 19-CV-02033-YGR
`
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`Dated: June 3, 2022
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`Case 4:19-cv-02033-YGR Document 245 Filed 06/06/22 Page 4 of 4
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`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 Schedule for
`Further Briefing on Lead Plaintiff’s Motion to Compel Production of Documents Withheld as
`Privileged. 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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`***
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`PURSUANT TO STIPULATION, IT IS SO ORDERED.
`
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`
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`HONORABLE JOSEPH C. SPERO
` CHIEF MAGISTRATE JUDGE
`
`- 3 -
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`STIPULATION AND [PROPOSED] ORDER RE: SCHEDULE
`FOR FURTHER BRIEFING ON MOTION TO COMPEL
`CASE NO. 19-CV-02033-YGR
`
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`Dated: June 6, 2022
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