Exhibit A — In re Plaid Inc. Privacy Litigation (Dkt. 55-2, N.D. Cal. No. 4:20-cv-03056)

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U.S. District Court for the Northern District of California · No. 4:20-cv-03056-DMR · Doc. 55-2 · 2020-07-28 · Docket on CourtListener

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Exhibit A
Case 4:20-cv-03056-DMR     Document 55-2     Filed 07/28/20     Page 1 of 3

1
From:
Dettmer, Ethan
Sent:
Monday, July 27, 2020 11:21 AM
To:
Shawn Kennedy
Cc:
Rachel Geman - Lieff Cabraser Heimann & Bernstein, LLP (rgeman@lchb.com); 
Christopher Cormier; Southwell, Alexander H.; Barrera, Abbey A.
Subject:
RE: Cottle - Joint Admin Motion / Stipulation
Dear Shawn – thanks for your email. If we don’t hear from the Court today, we will agree to a further filing – a further 
stipulation regarding consolidation and scheduling that tracks the earlier one and includes the Evans
plaintiffs. However, as you know from our earlier conversations, we believe that efficiency will be much better served 
for the parties and the Court if the CMC is pushed back to after the ruling on the motion to dismiss, so we don’t agree 
with your proposal regarding CMC scheduling. If we are going to agree to a further filing, it will need to make that 
clear. Please let me know if you’d like to discuss.
Thanks,
Ethan
From: Shawn Kennedy <skennedy@herrerapurdy.com> 
Sent: Monday, July 27, 2020 10:20 AM
To: Dettmer, Ethan <EDettmer@gibsondunn.com>
Cc: Rachel Geman - Lieff Cabraser Heimann & Bernstein, LLP (rgeman@lchb.com) <rgeman@lchb.com>; Christopher 
Cormier <ccormier@burnscharest.com>; Southwell, Alexander H. <ASouthwell@gibsondunn.com>; Barrera, Abbey A. 
<ABarrera@gibsondunn.com>
Subject: Re: Cottle - Joint Admin Motion / Stipulation
[External Email]
Ethan,
Please let me know what you decide on this - we will need to get something on file today one way or the 
other. Also, in the event Judge Ryu wants the CMC to go forward on its current date, what times may work for 
you tomorrow for a call to discuss the topics that need to be included in our Rule 26(f) report?
--Shawn
SHAWN M. KENNEDY
P A R T N E R
HERRERA PURDY LLP
4 5 9 0 M A C A R T H U R B LV D . , SUITE 5 0 0
N E W P O R T B E A C H , C A 9 2 6 6 0
T : 9 4 9 . 9 3 6 . 0 9 0 3
H E R R E R A P U R D Y . C O M
CONFIDENTIALITY NOTICE: This communication may contain information that is privileged and highly confidential. It is intended only for the use of those
addressees who are the sender’s intended recipients. If you have received this communication in error, please immediately notify Herrera Purdy LLP and permanently
delete or destroy all copies (electronic and printed) of the communication and any attachments thereto. Any unauthorized use or dissemination of this communication
and any attachments thereto is strictly prohibited. Your receipt of this communication does not create an attorney-client relationship between you and Herrera Purdy
LLP.
Case 4:20-cv-03056-DMR     Document 55-2     Filed 07/28/20     Page 2 of 3

2
From: Dettmer, Ethan <EDettmer@gibsondunn.com>
Sent: Friday, July 24, 2020 4:17 PM
To: Shawn Kennedy <skennedy@herrerapurdy.com>
Cc: Rachel Geman - Lieff Cabraser Heimann & Bernstein, LLP (rgeman@lchb.com) <rgeman@lchb.com>; Christopher 
Cormier <ccormier@burnscharest.com>; Southwell, Alexander H. <ASouthwell@gibsondunn.com>; Barrera, Abbey A. 
<ABarrera@gibsondunn.com>
Subject: RE: Cottle - Joint Admin Motion / Stipulation
Thanks, Shawn. Let me discuss with my client and get back to you.
From: Shawn Kennedy <skennedy@herrerapurdy.com> 
Sent: Friday, July 24, 2020 2:03 PM
To: Dettmer, Ethan <EDettmer@gibsondunn.com>
Cc: Rachel Geman - Lieff Cabraser Heimann & Bernstein, LLP (rgeman@lchb.com) <rgeman@lchb.com>; Christopher 
Cormier <ccormier@burnscharest.com>
Subject: Cottle - Joint Admin Motion / Stipulation
[External Email]
Hi Ethan,
In light of the impending deadline for the parties to file their joint Rule 26(f) report and related items, and now 
that the plaintiffs in the Evans case have filed a joinder in our stipulation consolidating the actions, we think it 
would be wise to file a new joint administrative motion or stipulation where we lay out the current procedural
status and demonstrate that the only things left for Judge Ryu to do are (1) grant the parties' stipulation and 
(2) set a new CMC for the consolidated actions. On the latter point, we suggest requesting that she continue 
the CMC until approximately 30 days after ruling on our stipulation, or as soon thereafter as the court's 
schedule allows.
Please let me know if Plaid will join in such a motion/stipulation.
Thanks, Shawn
SHAWN M. KENNEDY
P A R T N E R
HERRERA PURDY LLP
4 5 9 0 M A C A R T H U R B LV D . , SUITE 5 0 0
N E W P O R T B E A C H , C A 9 2 6 6 0
T : 9 4 9 . 9 3 6 . 0 9 0 3
H E R R E R A P U R D Y . C O M
CONFIDENTIALITY NOTICE: This communication may contain information that is privileged and highly confidential. It is intended only for the use of those
addressees who are the sender’s intended recipients. If you have received this communication in error, please immediately notify Herrera Purdy LLP and permanently
delete or destroy all copies (electronic and printed) of the communication and any attachments thereto. Any unauthorized use or dissemination of this communication
and any attachments thereto is strictly prohibited. Your receipt of this communication does not create an attorney-client relationship between you and Herrera Purdy
LLP.
This message may contain confidential and privileged information for the sole use of the intended recipient. Any review, 
disclosure, distribution by others or forwarding without express permission is strictly prohibited. If it has been sent to 
you in error, please reply to advise the sender of the error and then immediately delete this message. 
Please see our website at https://www.gibsondunn.com/ for information regarding the firm and/or our privacy policy. 
Case 4:20-cv-03056-DMR     Document 55-2     Filed 07/28/20     Page 3 of 3

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