Motion to Appoint Counsel and for Appointment as Lead Plaintiff by Rashesh Patel. (Attachments: # 1 Attachment Proposed Order)(Wood, Christopher)
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4902-9673-9229.v1
RETIREMENT SYSTEM, Individually and on Behalf of All Others Similarly Situated,
Plaintiff,
vs. ORACLE CORPORATION, et al.,
Defendants. ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 3:26-cv-00365 CLASS ACTION The Honorable Aleta A. Trauger MOTION FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF LEAD PLAINTIFF’S SELECTION OF LEAD COUNSEL
Class member and proposed lead plaintiff Rashesh Patel, by and through undersigned counsel, will and hereby does move this Court pursuant to the Private Securities Litigation Reform Act of 1995 (“PSLRA”), 15 U.S.C. §78u-4(a)(3)(B), for an order appointing Mr. Patel as Lead Plaintiff and approving his selection of Robbins Geller Rudman & Dowd LLP as Lead Counsel.1 This Motion is made on the grounds that Mr. Patel is the most adequate plaintiff to serve as lead
Because the PSLRA permits any “purported class member . . . including any motion by a class member who is not individually named as a plaintiff in the complaint” to file a motion for appointment as lead plaintiff, 15 U.S.C. §78u-4(a)(3)(B)(i), Mr. Patel cannot ascertain whether any other parties will also seek appointment as lead plaintiff until after the deadline expires on April 6th. Accordingly, Mr. Patel’s counsel respectfully requests that compliance with LR7.01(a)(1) be waived as to the unknown movants. See Franchi v. SmileDirectClub, Inc., 2020 WL 6479561, at *2 (M.D. Tenn. Jan. 27, 2020) (recognizing that “requirement comes into conflict with the provisions of the PSLRA” because “no prospective lead plaintiff can determine which, if any, other parties will also move for appointment until after the deadline to file has expired” and “waiv[ing] the requirement to comply with LR 7.01(a) in this instance”).
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4902-9673-9229.v1 plaintiff in the action. In support of this Motion, Mr. Patel submits herewith a Memorandum of Points and Authorities and the Declaration of Christopher M. Wood. DATED: April 6, 2026
ROBBINS GELLER RUDMAN & DOWD LLP CHRISTOPHER M. WOOD (BPR #032977) CHRISTOPHER H. LYONS (BPR #034853) JERRY E. MARTIN (BPR #20193) s/ Christopher M. Wood CHRISTOPHER M. WOOD 200 31st Avenue North Nashville, TN 37203 Telephone: 615/244-2203 [email protected] [email protected] ROBBINS GELLER RUDMAN & DOWD LLP DARREN J. ROBBINS DANIELLE S. MYERS 655 West Broadway, Suite 1900 San Diego, CA 92101-8498 Telephone: 619/231-1058 [email protected] [email protected] Proposed Lead Counsel for Proposed Lead Plaintiff
Transcribed from the public court filing · view original PDF
Public U.S. federal court record (district court docket 73110442, document 8). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.