Case 4:19-cv-02033-YGR Document 326 Filed 10/25/22 Page 1 of 3
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`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 DEADLINE TO
`SUBMIT STATEMENT OR
`DECLARATION IN SUPPORT OF
`SEALING REQUEST
`Hon. Yvonne Gonzalez Rogers
`
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`STIPULATION AND [PROPOSED] ORDER RE DEADLINE TO SUBMIT
`STATEMENT IN SUPPORT OF SEALING REQUEST
`CASE NO. 19-CV-02033-YGR
`
`

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`Case 4:19-cv-02033-YGR Document 326 Filed 10/25/22 Page 2 of 3
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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 October 20, 2022, Lead Plaintiff filed its Opposition to Defendants’
`Motion for Summary Judgment, and its Opposition to Defendants’ Motion to Exclude Expert
`Testimony (collectively, the “Oppositions”);
`WHEREAS, because the Oppositions make 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 three Administrative Motions to
`Consider Whether Another Party’s Material Should Be Sealed (the “Administrative Motions”)
`[Dkt. Nos. 321, 322, and 323];
`WHEREAS, in light of the volume of materials provisionally lodged under seal in
`connection with the Administrative Motions, Defendants have requested a one-week 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 Motions, and Lead Plaintiff does not
`oppose that request;
`NOW THEREFORE, it is stipulated and agreed among the undersigned Parties, and
`respectfully submitted for the Court’s approval as follows:
`Defendants shall file any statement and/or declaration in support of any sealing request in
`connection with the Administrative Motions no later than November 3, 2022.
`IT IS SO STIPULATED.
`
`Dated: October 25, 2022
`
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
`/s/ James N. Kramer
`JAMES N. KRAMER
`Attorneys for Defendants
`Apple Inc., Timothy Cook, and Luca Maestri
`
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`STIPULATION AND [PROPOSED] ORDER RE DEADLINE TO SUBMIT
`STATEMENT IN SUPPORT OF SEALING REQUEST
`CASE NO. 19-CV-02033-YGR
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`Case 4:19-cv-02033-YGR Document 326 Filed 10/25/22 Page 3 of 3
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`Dated: October 25, 2022
```
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`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 Deadline to
`Submit Statement or Declaration in Support of Sealing Request. 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:
`
`October 25, 2022
`
`HONORABLE YVONNE GONZALEZ ROGERS
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`- 2 -
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`STIPULATION AND [PROPOSED] ORDER RE DEADLINE TO SUBMIT
`STATEMENT IN SUPPORT OF SEALING REQUEST
`CASE NO. 19-CV-02033-YGR
`
`