Free Order - District Court of California - California

Case 4:07-cv-04972-CW

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1 COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 2 DENNIS J. HERMAN (220163) DANIEL J. PFEFFERBAUM (248631) 3 100 Pine Street, Suite 2600 San Francisco, CA 94111 4 Telephone: 415/288-4545 415/288-4534 (fax) 5 [email protected] [email protected] 6 Lead Counsel for Plaintiffs 7 8 9 10 11 JERRY TWINDE, On Behalf of Himself and ) 12 All Others Similarly Situated, ) ) 13 Plaintiff, ) ) 14 vs. ) ) 15 THRESHOLD PHARMACEUTICALS, INC., ) et al., ) 16 ) Defendants. ) 17 ) 18 19 20 21 22 23 24 25 26 27 28 No. 4:07-cv-04972-CW CLASS ACTION AMENDED STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR LEAD PLAINTIFF TO FILE CONSOLIDATED COMPLAINT AS MODIFIED UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION

Case 4:07-cv-04972-CW

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WHEREAS, pursuant to the Order entered by the Court on November 5, 2007, lead

2 plaintiff's consolidated complaint is due on December 20, 2007; 3 WHEREAS, lead plaintiff is still in the process of completing his investigation and

4 contacting potential witnesses and counsel for lead plaintiff has responsibilities related to multiple 5 summary judgment motions and Daubert challenges pending in other actions, including responses 6 due December 17, 2007 in one action and a hearing on December 20, 2007 in a different action; 7 WHEREAS, counsel for lead plaintiff has requested, and counsel for defendants has agreed,

8 that the deadline for lead plaintiff to file a consolidated complaint be extended to and include 9 January 15, 2008; 10 WHEREAS, the parties have agreed that defendants should have until February 29, 2008 to

11 respond by answering the consolidated complaint, moving to dismiss, or otherwise; 12 WHEREAS, if defendants file a motion to dismiss, the parties have agreed to modify the

13 briefing schedule such that lead plaintiff will file an opposition to defendants' motion to dismiss by 14 April 14, 2008; and defendants shall reply by May 29, 2008; and a hearing on any motion to dismiss 15 shall be scheduled for June 12, 2008; 16 IT IS THEREFORE STIPULATED AND AGREED by lead plaintiff and defendants,

17 through their respective counsel of record that, subject to the Court's approval, lead plaintiff shall 18 have until January 15, 2008 to file his consolidated complaint and defendants shall have until 19 February 29, 2008 to respond. If defendants move to dismiss, lead plaintiff will oppose by April 14, 20 2008 and defendants will reply by May 29, 2008. The hearing on any motion to dismiss shall be 21 scheduled for June 12, 2008. 22 DATED: December 14, 2007 23 24 25 26 27 28
AMENDED STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR LEAD PLAINTIFF TO FILE CONSOLIDATED COMPLAINT - 4:07-cv-04972-CW

COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP DENNIS J. HERMAN DANIEL J. PFEFFERBAUM

/s/ DANIEL J. PFEFFERBAUM

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Case 4:07-cv-04972-CW

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100 Pine Street, Suite 2600 San Francisco, CA 94111 Telephone: 415/288-4545 415/288-4534 (fax) Lead Counsel for Plaintiffs

4 5 DATED: December 14, 2007 6 7 8 9 10 11 12 13 14 Attorneys for Defendants THRESHOLD PHARMACEUTICALS, INC., HAROLD "BARRY" E. SELICK and JANET I. SWEARSON I, Daniel J. Pfefferbaum, am the ECF User whose ID and password are being used to file this /s/ LAURENCE A. WEISS 275 Middlefield Road Menlo Park, California 94025-3506 Telephone: 650/324-7000 650/324-0638 (fax) HELLER EHRMAN LLP LAURENCE A. WEISS

15 AMENDED STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR LEAD 16 PLAINTIFF TO FILE CONSOLIDATED COMPLAINT. In compliance with General Order 45, 17 X.B., I hereby attest that Laurence A. Weiss has concurred in this filing. 18 19 * 20 ORDER 21 PURSUANT TO STIPULATION, lead plaintiff shall have until January 15, 2008 to file his 22 consolidated complaint and defendants shall have until February 29, 2008 to respond. If defendants 23 file a motion to dismiss, plaintiff will oppose by April 14, 2008 and defendants will reply by 24 May 29, 2008. A hearing will be scheduled for June 12, 2008. 25 26 IT IS SO ORDERED. THE CASE MANAGEMENT CONFERENCE IS ALSO CONTINED TO 6/12/08 @ 2:00 p.m. 12/17/07 DATED: _________________________ ____________________________________ 27 THE HONORABLE CLAUDIA WILKEN UNITED STATES DISTRICT JUDGE 28 T:\casesSF\threshold\S_O00047892 amended.doc
AMENDED STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR LEAD PLAINTIFF TO FILE CONSOLIDATED COMPLAINT - 4:07-cv-04972-CW

/s/ DANIEL J. PFEFFERBAUM * *

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CERTIFICATE OF SERVICE I hereby certify that on December 14, 2007, I electronically filed the foregoing with the Clerk

3 of the Court using the CM/ECF system which will send notification of such filing to the e-mail 4 addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I have 5 mailed the foregoing document or paper via the United States Postal Service to the non-CM/ECF 6 participants indicated on the attached Manual Notice List. 7 I certify under penalty of perjury under the laws of the United States of America that the

8 foregoing is true and correct. Executed on December 14, 2007. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 s/ Daniel J. Pfefferbaum DANIEL J. PFEFFERBAUM COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 100 Pine Street, 26th Floor San Francisco, CA 94111 Telephone: 415/288-4545 415/288-4534 (fax) E-mail:[email protected]

CAND-ECF Case 4:07-cv-04972-CW

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Mailing Information for a Case 4:07-cv-04972-CW
Electronic Mail Notice List
The following are those who are currently on the list to receive e-mail notices for this case. Kevin Anthony Burke [email protected] Michael L. Charlson [email protected],[email protected],[email protected],[email protected],karen.strong@he Marc S. Henzel [email protected] Dennis J. Herman [email protected],[email protected],[email protected],[email protected],[email protected] Alexander M.R. Lyon [email protected],[email protected] Daniel Jacob Pfefferbaum [email protected] Darren Jay Robbins [email protected] Samuel H. Rudman [email protected] Laurence Andrew Weiss [email protected]

Manual Notice List
The following is the list of attorneys who are not on the list to receive e-mail notices for this case (who therefore require manual noticing). You may wish to use your mouse to select and copy this list into your word processing program in order to create notices or labels for these recipients.
Mary K. Blasy Coughlin Stoia Geller Rudman & Robbins LLP 655 West Broadway Suite 1900 San Diego, CA 92101

https://ecf.cand.uscourts.gov/cgi-bin/MailList.pl?189696632385648-L_685_0-1

12/14/2007