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`Case 4:19-cv-02033-YGR Document 256 Filed 07/12/22 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]
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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:
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`ALL ACTIONS.
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`Case No. 4:19-cv-02033-YGR
`CLASS ACTION
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`STIPULATION AND [PROPOSED]
`ORDER REGARDING: (1) BRIEFING
`SCHEDULE FOR LEAD PLAINTIFF’S
`MOTION FOR LEAVE TO FILE THE
`PROPOSED SECOND AMENDED
`CLASS ACTION COMPLAINT; AND (2)
`EXPERT DEPOSITIONS DEADLINE
`
`
`STIPULATION AND [PROPOSED] ORDER RE BRIEFING
`SCHEDULE FOR LEAD PLT’S MOTION FOR LEAVE TO FILE SAC
`CASE NO. 19-CV-02033-YGR
`
`
`

`

`Case 4:19-cv-02033-YGR Document 256 Filed 07/12/22 Page 2 of 4
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`This Stipulation is entered into by and among Lead Plaintiff Norfolk County Council as
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`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 July 5, 2022, Lead Plaintiff filed a Motion for Leave to File the Proposed
`Second Amended Class Action Complaint (the “Motion”) [Dkt. No. 250];
`WHEREAS, in light of competing deadlines, Defendants have requested a one-week
`extension of the deadline set by the Local Rules for their opposition to the Motion, and Lead
`Plaintiff does not oppose that request;
`WHEREAS, because the Motion makes reference to a substantial volume of discovery
`materials that Defendants have designated as Confidential or Highly Confidential pursuant to the
`Stipulated Protective Order, Lead Plaintiff has also filed an Administrative Motion to Consider
`Whether Another Party’s Material Should Be Sealed (the “Administrative Motion”) [Dkt. No.
`249];
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`- 1 -
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`WHEREAS, in light of competing deadlines, Defendants have requested an extension of
`the deadline set by Local Rule 79-5(f)(3) to file a statement and/or declaration in support of any
`sealing request in connection with the Administrative Motion, to align that deadline with the
`deadline for Defendants’ opposition to the Motion, and Lead Plaintiff does not oppose that
`request;
`WHEREAS, the Court’s Case Management Order [Dkt. No. 128] set a deadline of July
`22, 2022 for the Parties to complete expert depositions;
`WHEREAS, Lead Plaintiff has requested a one-week extension of the deadline for expert
`depositions for the sole purpose of permitting the deposition of one of Lead Plaintiff’s experts to
`proceed during the week of July 25, 2022, and Defendants do not oppose that request;
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`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 Motion no later than July 26, 2022;
`2.
`Lead Plaintiff shall file any reply in support of the Motion no later than August 5,
`STIPULATION AND [PROPOSED] ORDER RE BRIEFING
`SCHEDULE FOR LEAD PLT’S MOTION FOR LEAVE TO FILE SAC
`CASE NO. 19-CV-02033-YGR
`
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`
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`

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`Case 4:19-cv-02033-YGR Document 256 Filed 07/12/22 Page 3 of 4
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`2022;
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`3.
`Defendants shall file any statement and/or declaration in support of any sealing
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`request in connection with the Administrative Motion no later than July 26, 2022.
`4.
`The July 22, 2022 deadline for depositions of other expert witnesses remains
`unchanged, except that the deposition of one of Lead Plaintiff’s experts may be completed by
`July 29, 2022.
`IT IS SO STIPULATED.
`
`
`Dated: July 8, 2022
`
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
`
`
`Dated: July 8, 2022
`
`
` /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 BRIEFING
`SCHEDULE FOR LEAD PLT’S MOTION FOR LEAVE TO FILE SAC
`CASE NO. 19-CV-02033-YGR
`
`

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`Case 4:19-cv-02033-YGR Document 256 Filed 07/12/22 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 Briefing Schedule
`for Lead Plaintiff’s Motion for Leave to File the Proposed Second Amended Complaint. 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
`
`***
`
`PURSUANT TO STIPULATION, IT IS SO ORDERED.
`
`Dated:
`
`July 12, 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 MOTION FOR LEAVE TO FILE SAC
`CASE NO. 19-CV-02033-YGR
`
`