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In re Google Inc. S'Holder Derivative Litig.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION
Nov 17, 2011
Master File No. CV-11-04248-PJH (N.D. Cal. Nov. 17, 2011)

Opinion

Master File No. CV-11-04248-PJH

11-17-2011

In re GOOGLE INC. SHAREHOLDER DERIVATIVE LITIGATION This Document Relates To: ALL ACTIONS

WILSON SONSINI GOODRICH & ROSATI Professional Corporation By: Elizabeth C. Peterson Attorneys for Defendants and Nominal Defendant Google Inc. ROBBINS GELLER RUDMAN & DOWD LLP DARREN J. ROBBINS TRAVIS E. DOWNS III BENNY C. GOODMAN III ERIK W. LUEDEKE By: Benny C. Goodman III ROBBINS GELLERRUDMAN & DOWD LLP SHAWN A. WILLIAMS ROBBINS UMEDA LLP BRIAN J. ROBBINS FELIPE J. ARROYO SHANE P. SANDERS GINA STASSI POMERANTZHAUDEKGROSSMAN & GROSS LLP MARC I. GROSS JEREMY A. LIEBERMAN JASON S.COWART FEI-LU QIAN POMERANTZHAUDEKGROSSMAN & GROSS LLP PATRICK V. DAHLSTROM Lead Counsel for Plaintiffs


BORIS FELDMAN, State Bar No. 128838

ELIZABETH C. PETERSON, State Bar No. 194561

CHERYL FOUNG, State Bar No. 108868

DIANE M. WALTERS, State Bar No. 148136

BRYSON S. SANTAGUIDA, State Bar No. 255173

WILSON SONSINI GOODRICH & ROSATI

Professional Corporation

Attorneys for Defendants Larry Page, Sergey

Brin, Eric E. Schmidt, L. John Doerr, John L.

Hennessy, Paul S. Otellini, K. Ram Shriram,

Shirley M. Tilghman, Nikesh Arora, Patrick

Pichette, and Nominal Defendant Google Inc.

STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING

SCHEDULE FOR DEFENDANTS' RESPONSE TO COMPLAINT AS MODIFIED


JUDGE: Hon. Phyllis J. Hamilton

WHEREAS, on October 24, 2011, plaintiffs filed their Verified Consolidated Shareholder Derivative Complaint (the "Complaint");

WHEREAS, pursuant to the September 19, 2011 Stipulation and Order Consolidating Actions and Appointing Lead Counsel entered by the Court (Dkt. #15), Defendants have thirty days from the October 24, 2011 filing of the Complaint, or until November 23, 2011, to respond to the Complaint;

WHEREAS, due to intervening circumstances, including a death in the immediate family of one of Defendants' attorneys, Defendants have requested, subject to Court approval, that the deadline for Defendants to respond to the Complaint be extended until December 14, 2011, and plaintiffs have agreed to the requested extension;

WHEREAS, the parties have further agreed, subject to Court approval, that plaintiffs' opposition to Defendants' motion(s) to dismiss shall be filed no later than January 31, 2012, and Defendants' reply memoranda shall be filed no later than March 1, 2012;

WHEREAS, the requested extension is not for the purpose of delay and will not prejudice any party;

WHEREAS, the parties have further met and conferred regarding applicable page-length requirements and have agreed that in the event that Defendants file a consolidated motion in response to the Complaint, rather than multiple, individual motions, Defendants shall have the option to file a single, consolidated motion not to exceed 50 pages, in lieu of filing separate 25-page briefs;

WHEREAS, in the event that Defendants file a single, consolidated motion in response to the Complaint, Plaintiffs shall have the option of filing a single, consolidated opposition brief of equal length;

THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned, subject to Court approval, as follows:

1. Defendants shall have until December 14, 2011 to respond to the Complaint;

2. Plaintiffs shall have until January 31, 2012 to file their brief(s) in opposition to Defendants' motion(s) to dismiss;

3. Defendants shall have until March 1, 2012 to file their reply brief(s);

4. Defendants shall have the option to file a single, consolidated motion in response to the Complaint not to exceed 40 pages, in lieu of filing separate 25-page briefs; and

5. In the event that Defendants file a single, consolidated motion, plaintiffs shall have the option of filing a single, consolidated opposition of equal length.

Respectfully submitted,

WILSON SONSINI GOODRICH & ROSATI

Professional Corporation

By: Elizabeth C. Peterson

Attorneys for Defendants and Nominal

Defendant Google Inc.

ROBBINS GELLER RUDMAN

& DOWD LLP

DARREN J. ROBBINS

TRAVIS E. DOWNS III

BENNY C. GOODMAN III

ERIK W. LUEDEKE

By: Benny C. Goodman III

ROBBINS GELLERRUDMAN

& DOWD LLP

SHAWN A. WILLIAMS

ROBBINS UMEDA LLP

BRIAN J. ROBBINS

FELIPE J. ARROYO

SHANE P. SANDERS

GINA STASSI

POMERANTZHAUDEKGROSSMAN

& GROSS LLP

MARC I. GROSS

JEREMY A. LIEBERMAN

JASON S.COWART

FEI-LU QIAN

POMERANTZHAUDEKGROSSMAN

& GROSS LLP

PATRICK V. DAHLSTROM

Lead Counsel for Plaintiffs I, Elizabeth C. Peterson, am the ECF user whose ID and password are being used to file this STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULE FOR DEFENDANTS' RESPONSE TO COMPLAINT. In compliance with General Order 45, X.B., I hereby attest that Benny C. Goodman III has concurred in this filing.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

THE HONORABLE PHYLLIS J. HAMILTON

UNITED STATES DISTRICT JUDGE


Summaries of

In re Google Inc. S'Holder Derivative Litig.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION
Nov 17, 2011
Master File No. CV-11-04248-PJH (N.D. Cal. Nov. 17, 2011)
Case details for

In re Google Inc. S'Holder Derivative Litig.

Case Details

Full title:In re GOOGLE INC. SHAREHOLDER DERIVATIVE LITIGATION This Document Relates…

Court:UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION

Date published: Nov 17, 2011

Citations

Master File No. CV-11-04248-PJH (N.D. Cal. Nov. 17, 2011)