Opinion
Case No.: 3:12-cv-00225-SC
03-28-2013
In re NETFLIX, INC., SECURITIES LITIGATION This Document Relates To: ALL ACTIONS.
WILSON SONSINI GOODRICH & ROSATI Professional Corporation Rodney G. Strickland Attorneys for Defendants Netflix Inc., Reed Hastings, David Wells, and Barry McCarthy LABATON SUCHAROW LLP Jonathan M. Plasse Stephen W. Tountas Serena Hallowell Stephen W. Tountas Lead Counsel for Lead Plaintiffs
KEITH E. EGGLETON, State Bar No. 159842
Email: keggleton@wsgr.com
BORIS FELDMAN, State Bar No. 128838
Email: boris.feldman@wsgr.com
RODNEY G. STRICKLAND, State Bar No. 161934
Email: rstrickland@wsgr.com
LUKE A. LISS, State Bar No. 247520
Email: lliss@wsgr.com
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
650 Page Mill Road Palo Alto, CA 94304-1050
Telephone: (650) 493-9300 Facsimile: (650) 565-5100
Attorneys for Defendants
Netflix, Inc., Reed Hastings, David Wells, and
Barry McCarthy
CONSOLIDATED CLASS ACTION
STIPULATION AND [PROPOSED] SCHEDULING ORDER
WHEREAS, lead plaintiffs Arkansas Teacher Retirement System and State-Boston Retirement System ("Lead Plaintiffs") filed the First Amended Consolidated Class Action Complaint for Violations of the Federal Securities Laws (the "Complaint") against defendants Netflix, Inc., Reed Hastings, David Wells, and Barry McCarthy (collectively, "Defendants") on March 22, 2013;
WHEREAS, pursuant to Federal Rules of Civil Procedure 6(d) and 15(a)(3), Defendants' response to the Complaint is to be filed on or before April 8, 2013;
WHEREAS, Defendants intend to file a motion to dismiss the Complaint (the "Motion to Dismiss");
WHEREAS, the parties have conferred and agree that setting an appropriate schedule regarding the Motion to Dismiss and related briefing is in the best interest of the parties;
THEREFORE, SUBJECT TO THE APPROVAL OF THE COURT, IT IS HEREBY STIPULATED AND AGREED, by the undersigned, as follows:
1. Defendants' Motion to Dismiss shall be filed on or before April 24, 2013.
2. Lead Plaintiffs' opposition to Defendants' Motion to Dismiss shall be filed on or before May 24, 2013.
3. Defendants' reply memorandum shall be filed on or before June 7, 2013.
4. Prior to the filing of the Motion to Dismiss, the parties shall meet and confer regarding a hearing date for the Motion to Dismiss that is convenient for the parties and the Court.
Respectfully submitted,
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
By: ________
Rodney G. Strickland
Attorneys for Defendants Netflix Inc., Reed
Hastings, David Wells, and Barry McCarthy
LABATON SUCHAROW LLP
Jonathan M. Plasse
Stephen W. Tountas Serena Hallowell
By: ________
Stephen W. Tountas
Lead Counsel for Lead Plaintiffs I, Rodney G. Strickland, am the ECF User whose ID and password are being used to file this STIPULATION AND [PROPOSED] SCHEDULING ORDER. In compliance with Civil L.R. 5-1(i)(3), I hereby attest that the Stephen W. Tountas has concurred in this filing.
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
1. Defendants' Motion to Dismiss shall be filed on or before April 24, 2013.
2. Lead Plaintiffs' opposition to Defendants' Motion to Dismiss shall be filed on or before May 24, 2013.
3. Defendants' reply memorandum shall be filed on or before June 7, 2013.
4. Prior to the filing of the Motion to Dismiss, the parties shall meet and confer regarding a hearing date for the Motion to Dismiss that is convenient for the parties and the Court.
__________________
Honorable Samuel Conti
United States District Judge