STIPULATED PRELIMINARY APPROVAL SCHEDULE AND [PROPOSED] ORDER 

Case No. 4:17-CV-00554-YGR 

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JORDAN ETH (CA SBN 121617) 

JEth@mofo.com 

MARK R.S. FOSTER (CA SBN 2236822) 

MFoster@mofo.com 

AMANDA TRELEAVEN (CA SBN 266934) 

ATreleaven@mofo.com 

SU-HAN WANG (CA SBN 284863) 

SWang@mofo.com 

MORRISON & FOERSTER LLP

425 Market Street 

San Francisco, California 94105-2482 

Telephone: (415) 268-7000 

Facsimile: (415) 268-7522 

ERIK J. OLSON (CA SBN 175815) 

EJOlson@mofo.com 

MORRISON & FOERSTER LLP

755 Page Mill Road 

Palo Alto, California 94304-1018 

Telephone: (650) 813-5600 

Facsimile: (650) 494-0792 

Attorneys for Defendants 

RH, GARY FRIEDMAN, and KAREN BOONE 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

OAKLAND DIVISION

IN RE RH, INC. SECURITIES LITIGATION 

Case No. 4:17-cv-00554-YGR 

CLASS ACTION 

STIPULATED PRELIMINARY 

APPROVAL SCHEDULE AND 

[PROPOSED] ORDER 
STIPULATED PRELIMINARY APPROVAL SCHEDULE AND [PROPOSED] ORDER 

Case No. 4:17-CV-00554-YGR 1 

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In accordance with Local Rule 7-12, Lead Plaintiffs Public School Teachers’ Pension & 

Retirement Fund of Chicago and Arkansas Teacher Retirement System (“Lead Plaintiffs”) and 

Defendants RH, Gary Friedman, and Karen Boone (“Defendants” and collectively with Lead 

Plaintiffs, the “Parties”), by and through their undersigned counsel, submit the following stipulation 

and proposed order: 

WHEREAS, on March 1, 2019, the Parties participated in an all-day mediation before the 

former United States District Judge Layn R. Phillips and thereafter engaged in further settlement 

negotiations culminating in an agreement in principle to a class-wide settlement, the basic terms of 

which are set forth in a fully executed Memorandum of Understanding dated March 21, 2019; 

WHEREAS, the proposed settlement, if approved by the Court, will fully resolve all 

pending claims in the action; 

NOW, THEREFORE, the Parties hereby stipulate and agree as follows, and respectfully 

request that the Court enter the [Proposed] Order: 

1. All pending deadlines shall be vacated; 

2. Lead Plaintiffs shall file a motion for preliminary approval of the proposed 

settlement on or before May 6, 2019; 

3. Any opposition to the motion for preliminary approval shall be filed on or before 

May 20, 2019; 

4. Lead Plaintiffs’ reply in support of preliminary approval shall be filed on or before 

May 27, 2019; 

5. Lead Plaintiffs shall notice the hearing on their motion for preliminary approval 

for June 18, 2019 at 2:00 p.m. 
STIPULATED PRELIMINARY APPROVAL SCHEDULE AND [PROPOSED] ORDER 

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Dated: March 25, 2019 MORRISON & FOERSTER LLP 

By: /s/ Mark R.S. Foster

Mark R.S. Foster 

Attorneys for Defendants 

RH, Gary Friedman, and Karen Boone 

Dated: March 25, 2019 BERNSTEIN LITOWITZ BERGER 

& GROSSMANN LLP 

By: /s/ Jonathan D. Uslaner 

Jonathan D. Uslaner 

Attorneys for Lead Plaintiffs Public School 

Teachers’ Pension & Retirement Fund of 

Chicago and Arkansas Teacher Retirement 

System and Lead Counsel for the Class 

 
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ORDER 

PURSUANT TO STIPULATION, IT IS SO ORDERED. 

Dated: 

 

HONORABLE YVONNE GONZALEZ ROGERS 

UNITED STATES DISTRICT JUDGE 

 

March 27, 2019
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ATTESTATION (CIVIL LOCAL RULE 5-1(i)(3)) 

In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of 

this document has been obtained from the signatories. 

Dated: March 25, 2019 MORRISON & FOERSTER LLP 

 /s/ Mark R.S. Foster 

 Mark R.S. Foster