Khan v. ChargePoint Holdings, Inc. et al

5:23-cv-06172CandMar 13, 2026

Full text

S TIPULATION AND [P ROPOSED ] ORDER R EGARDING B RIEFING S CHEDULE FOR M OTION TO DISMISS
C ASE NO. 5:23-CV-06172-NW
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Sara B. Brody (SBN 130222)
sbrody@sidley.com
Jaime A. Bartlett (SBN 251825)
jbartlett@sidley.com
Matthew P. Henry (SBN 308878)
mhenry@sidley.com
Chaddy G. Georges (SBN 335546)
cgeorges@sidley.com
SIDLEY AUSTIN LLP
101 California Street
Suite 3500
San Francisco, CA 94111
Attorneys for Defendants
ChargePoint Holdings, Inc., Pasquale Romano,
Rex S. Jackson, and Michael Hughes
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
FAROOQ KHAN, Individually and on Behalf of
All Others Similarly Situated,
Plaintiff,
vs.
CHARGEPOINT HOLDINGS, INC., et al.,
Defendants.
Case No. 5:23-cv-06172-NW
STIPULATION AND [PROPOSED]
ORDER REGARDING BRIEFING
SCHEDULE FOR DEFENDANTS’
MOTION TO DISMISS PLAINTIFFS’
THIRD AMENDED COMPLAINT
Assigned to: Hon. Noël Wise
Case 5:23-cv-06172-NW Document 152 Filed 03/13/26 Page 1 of 5
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Pursuant to Civil Local Rules 6-2 and 7-12, Lead Plaintiffs Shahram Afshani and Paulina
Afshani Schwartz (“Lead Plaintiffs”) and Defendants ChargePoint Holdings, Inc., Pasquale Romano,
Rex S. Jackson, and Michael Hughes (“Defendants” and together with Lead Plaintiffs, the “Parties”)
by and through their undersigned counsel, enter into the following stipulation.
WHEREAS, on February 20, 2026 the Court entered an order dismissing Lead Plaintiffs’
Second Amended Complaint with leave to amend, and directing Lead Plaintiffs to file any amended
complaint within 14 days (Dkt. 149);
WHEREAS, on March 6, 2026, pursuant to the Court’s order, Lead Plaintiffs filed their
Third Amended Complaint (Dkt. 150);
WHEREAS, pursuant to Federal Rule of Civil Procedure 15(a)(3), Defendants’ deadline to
respond to the Third Amended Complaint is March 20, 2026;
WHEREAS, Defendants anticipate filing a motion to dismiss the Third Amended Complaint
on March 20, 2026;
WHEREAS, pursuant to Civil Local Rule 7-3(a), Lead Plaintiffs’ opposition to Defendants’
motion would be due on April 3, 2026;
WHEREAS, pursuant to Civil Local Rule 7-3(c), Defendants’ reply in support of their
motion would be due on April 10, 2026;
WHEREAS, the time period of April 3, 2026 through April 10, 2026 encompasses multiple
religious holidays, including Good Friday, Easter, and Passover;
WHEREAS, in light of the religious holidays, the Parties agree that good cause exists to
extend Defendants’ deadline for their reply from April 10, 2026 to April 13, 2026; and
WHEREAS, the Parties agree that prior to filing their motion, and subject to the availability
of the Court, Defendants shall request that their motion be heard on or after May 13, 2026.
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, and respectfully
requested, by and among the parties hereto, through their undersigned counsel of record, as follows:
1. 	In accordance with the applicable rules, Defendants shall file their motion to dismiss
the Third Amended Complaint on March 20, 2026, and Lead Plaintiffs shall file their opposition on
April 3, 2026; and
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C ASE NO. 5:23-CV-06172-NW
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2. 	In light of the religious holidays, Defendants shall file their reply in support of their
motion on April 13, 2026.
IT IS SO STIPULATED.
Date: March 11, 2026 	Respectfully submitted,
By: /s/ Jaime A. Bartlett
Sara B. Brody (SBN 130222)
sbrody@sidley.com
Jaime A. Bartlett (SBN 251825)
jbartlett@sidley.com
Matthew P. Henry (SBN 308878)
mhenry@sidley.com
Chaddy G. Georges (SBN 335546)
cgeorges@sidley.com
SIDLEY AUSTIN LLP
101 California Street
Suite 3500
San Francisco, CA 94111
Attorneys for Defendants
ChargePoint Holdings, Inc., Pasquale Romano,
Rex S. Jackson, and Michael Hughes
Date: March 11, 2026 	Respectfully submitted,
By: /s/ Lucas E. Gilmore
Lucas E. Gilmore (SBN 250893)
Reed R. Kathrein (SBN 139304)
HAGENS BERMAN SOBOL SHAPIRO
LLP
715 Hearst Avenue, Suite 300
Berkeley, CA 94710
Telephone: (510) 725-3000
Facsimile: (510) 725-3001
lucasg@hbsslaw.com
reed@hbsslaw.com
Raffi Melanson (pro hac vice)
HAGENS BERMAN SOBOL SHAPIRO
LLP
1 Faneuil Hall Sq., 5th Floor
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Boston, MA 02109
Telephone: (617) 482-3700
Email: raffim@hbsslaw.com
Lead Counsel for Lead Plaintiffs Shahram
Afshani and Paulina Afshani Schwartz
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[PROPOSED] ORDER
Having reviewed the Parties’ Stipulation and good cause appearing therefore, IT IS
HEREBY ORDERED:
1. 	In accordance with the applicable rules, Defendants shall file their motion to dismiss
the Third Amended Complaint on March 20, 2026, and Lead Plaintiffs shall file their opposition on
April 3, 2026; and
2. 	In light of the religious holidays, Defendants shall file their reply in support of their
motion on April 13, 2026.
Dated: __________________, 2026 	_______________________________________
Hon. Noël Wise
United States District Judge
March 13
Case 5:23-cv-06172-NW Document 152 Filed 03/13/26 Page 5 of 5

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