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`Case 4:19-cv-02033-YGR Document 307 Filed 09/14/22 Page 1 of 3
`
`
`
`
`
`JAMES N. KRAMER (SBN 154709)
`jkramer@orrick.com
`MICHAEL D. TORPEY (SBN 79424)
`mtorpey@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
`SCHEDULES FOR DEFENDANTS’
`MOTION FOR SUMMARY JUDGMENT
`AND THE PARTIES’ MOTIONS TO
`EXCLUDE EXPERT TESTIMONY
`Hon. Yvonne Gonzalez Rogers
`
`
`STIPULATION AND [PROPOSED] ORDER RE
`BRIEFING SCHEDULES
`CASE NO. 19-CV-02033-YGR
`
`
`
`
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`Case 4:19-cv-02033-YGR Document 307 Filed 09/14/22 Page 2 of 3
`
`
`
`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 September 9, 2022, Defendants filed a Motion for Summary Judgment
`(Dkt. No. 293);
`WHEREAS, on September 9, 2022, Lead Plaintiff filed a Motion to Exclude Opinion
`Testimony of Defendants’ Proposed Experts (Dkt. No. 301), and Defendants filed a Motion to
`Exclude Expert Testimony (Dkt. No. 292) (collectively, the “Daubert Motions”);
`WHEREAS, the Court’s Case Management Order (Dkt. No. 128) set a deadline of
`September 9, 2022 for Summary Judgment and Daubert Motions, but did not set deadlines for
`opposition and reply briefing;
`WHERAS, the Parties have met and conferred and reached an agreement to set a briefing
`schedule, subject to the Court’s approval, for Defendants’ Motion for Summary Judgment and the
`Parties’ Daubert Motions;
`
`NOW THEREFORE, it is stipulated and agreed among the undersigned Parties, and
`respectfully submitted for the Court’s approval as follows:
`1.
`Lead Plaintiff shall file any opposition to the Motion for Summary Judgment, and
`the Parties shall file any oppositions to the Daubert Motions, no later than October 20, 2022;
`2.
`Defendants shall file any reply in support of the Motion for Summary Judgment,
`and the Parties shall file any replies in support of the Daubert Motions, no later than November
`17, 2022.
`IT IS SO STIPULATED.
`
`
`
`
`
`
`
`
`
`- 1 -
`
`STIPULATION AND [PROPOSED] ORDER RE
`BRIEFING SCHEDULES
`CASE NO. 19-CV-02033-YGR
`
`
`
`Case 4:19-cv-02033-YGR Document 307 Filed 09/14/22 Page 3 of 3
`
`Dated: September 12, 2022
`
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
` /s/ James N. Kramer
`JAMES N. KRAMER
`Attorneys for Defendants
`Apple Inc., Timothy Cook and Luca Maestri
`
`Dated: September 12, 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
`Schedules for Defendants’ Motion for Summary Judgment and the Parties’ Motions to Exclude
`Expert Testimony. 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:
`
`September 14, 2022
`
`HONORABLE YVONNE GONZALEZ ROGERS
`
`- 2 -
`
`STIPULATION AND [PROPOSED] ORDER RE
`BRIEFING SCHEDULES
`CASE NO. 19-CV-02033-YGR
`
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`
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