`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Case 4:19-cv-02033-YGR Document 340 Filed 02/07/23 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 TO CONTINUE HEARING ON
`LEAD PLAINTIFF’S SUPPLEMENTAL
`MOTION TO CERTIFY CLASS OF
`APPLE OPTIONS INVESTORS AND
`DEFENDANTS’ MOTION FOR
`SUMMARY JUDGMENT
`Hon. Yvonne Gonzalez Rogers
`
`
`STIPULATION AND [PROPOSED] ORDER TO
`CONTINUE HEARING
`CASE NO. 19-CV-02033-YGR
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Case 4:19-cv-02033-YGR Document 340 Filed 02/07/23 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 April 15, 2022, Lead Plaintiff filed a Supplemental Motion to Certify
`Class of Apple Options Investors (Dkt. No. 239, the “Supplemental Class Certification Motion”);
`WHEREAS, on September 9, 2022, Defendants filed a Motion for Summary Judgment
`(Dkt. No. 293);
`WHEREAS, on February 6, 2023, the Court set an in-person hearing to take place on
`March 7, 2023 at 2 p.m. for both Lead Plaintiff’s Supplemental Class Certification Motion and
`Defendants’ Motion for Summary Judgment (Dkt. No 338);
`WHEREAS, lead counsel for Defendants has a previously scheduled commitment that
`requires him to travel outside of the Bay Area on March 7, 2023, and therefore respectfully
`requests, subject to the Court’s availability, that the Court continue the hearing by one week to
`March 14, 2023;
`WHEREAS, counsel for Lead Plaintiff does not oppose the requested continuance to
`March 14, 2023;
`
`NOW THEREFORE, it is stipulated and agreed among the undersigned Parties, and
`respectfully submitted for the Court’s approval as follows:
`The hearing on Lead Plaintiff’s Supplemental Class Certification Motion and Defendants’
`Motion for Summary Judgment is continued to March 14, 2023, at 2 p.m.
`IT IS SO STIPULATED.
`
`
`
`
`
`
`
`
`
`- 1 -
`
`STIPULATION AND [PROPOSED] ORDER TO
`CONTINUE HEARING
`CASE NO. 19-CV-02033-YGR
`
`
`
`Case 4:19-cv-02033-YGR Document 340 Filed 02/07/23 Page 3 of 3
`
`Dated: February 7, 2023
`
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
`/s/ James Kramer
`JAMES N. KRAMER
`Attorneys for Defendants
`Apple Inc., Timothy Cook, and Luca Maestri
`
`Dated: February 7, 2023
`
`ROBBINS GELLER RUDMAN & DOWD LLP
`
`/s/ Shawn 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 to Continue Hearing on
`Lead Plaintiff’s Supplemental Motion to Certify Class and Defendants’ Motion for Summary
`Judgment. In compliance with General Order 45, X.B., I hereby attest that Shawn A. Williams
`has concurred in this filing.
`
` /s/ James Kramer
`JAMES N. KRAMER
`
`PURSUANT TO STIPULATION, IT IS SO ORDERED.
`
`***
`
`Dated:
`February 7, 2023
`
`HONORABLE YVONNE GONZALEZ ROGERS
`
`- 2 -
`
`STIPULATION AND [PROPOSED] ORDER TO
`CONTINUE HEARING
`CASE NO. 19-CV-02033-YGR
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`