United States District Court, D. Nevada
GLEN HARTSOCK, Individually and on behalf of all others similarly situated, Plaintiff,
SPECTRUM PHARMACEUTICALS, INC., and RAJESH C. SHROTRIYA, Defendants. OLUTAYO AYENI, Individually and on behalf of all others similarly situated, Plaintiff,
SPECTRUM PHARMACEUTICALS, INC., RAJESH C. SHROTRIYA, KURT A. GUSTAFSON, JOSEPH TURGEON, and LEE ALLEN, Defendants.
LEVERTY & ASSOCIATES LAW CHTD. Patrick R. Leverty, Esq.
(Nevada Bar No. 8840) [Proposed] Liaison Counsel for Lead
Plaintiff Movants Michael Bestwick and Mark Hawkins
ROSEN LAW FIRM, P.A. Laurence M. Rosen, Esq. Phillip Kim,
Esq. BRONSTEIN, GEWIRTZ & GROSSMAN, LLC Peretz Bronstein
Shimon Yiftach Co-Lead Counsel for Counsel for Lead Plaintiff
Movants Michael Bestwick and Mark Hawkins
COOKSEY, TOOLEN, GAGE, DUFFY & WOOG Griffith H. Hayes
(Nevada Bar No. 7374) [Proposed] Local Counsel for Lead
Plaintiff Movant Anchorage Police & Fire Retirement
BLEICHMAR FONTI & AULD LLP Javier Bleichmar Cynthia
Hanawalt [Proposed] Counsel for Lead Plaintiff Movant
Anchorage Police & Fire Retirement System and Proposed
OFFICE OF TELIA U. WILLIAMS Telia U. Williams, Esq. Nevada
Bar No. 9359 BLOCK & LEVITON LLP Jeffrey C. Block, Esq.
Joel A. Fleming, Esq. Counsel for Plaintiff Glen Hartsock
Counsel for Plaintiff Glen Hartsock Counsel for Spectrum
Pharmaceuticals, Inc., Rajesh C. Shrotriya, Kurt A.
Gustafson, Joseph Turgeon, and Lee Allen
STIPULATION AND [PROPOSED] ORDER
Honorable Richard F. Boulware II U.S. District Court Judge
on September 21, 2016, the action Olutayo Ayeni v.
Spectrum Pharmaceuticals, Inc., et al., Docket No.
16-cv-07074 (C.D.Cal. Sep, 21, 2016) was commenced in the
U.S. District Court for the Central District of California
on September 28, 2016, the related action styled as
Hartsock v. Spectrum Pharmaceuticals, Inc. et al.,
Docket No. 2:16-cv-02279 (D. Nev. Sept 28, 2016) (the
“Hartsock Action”) was filed in this Court,
currently pending before Judge Richard F. Boulware, II;
on November 15, 2016, U.S. District Judge Dale S. Fischer
ordered the transfer of the Ayeni Action to this court and
the Ayeni Action is now pending before Judge Kent J. Dawson;
the complaints in both the Ayeni Action and Hartsock Action
assert claims under Sections 10(b) and 20(a) of the
Securities Exchange Act of 1934 (the “Exchange
Act”) on behalf of a putative class which are subject
to the Private Securities Litigation Reform Act of 1995
(“PSLRA”), which provides for a specific process
for the appointment of lead plaintiff and lead counsel to
represent the putative class;
Lead Plaintiff and Lead Counsel have not yet been appointed
pursuant to Section 21D(a) of the Exchange Act;
on November 21, 2016, Movant Anchorage Police & Fire
Retirement System and Movants Michael Bestwick and Mark
Hawkins filed two competing motions to Consolidate Related
Actions, Appoint Lead Plaintiffs and Approve Counsel in the
Hartsock Action; and
on January 10, 2017, the Court filed a Notice Regarding
Intention to Dismiss Pursuant to Rule 4(m) of the Federal
Rules of Civil Procedure in the Hartsock Action;
HEREBY STIPULATED AND AGREED among the undersigned parties,
subject to the ...