Doe I et al v. Cisco Systems, Inc. et al

Filing 41

*** FILED IN ERROR. REFER TO DOCUMENT 43 . *** Joint MOTION for Leave to File Excess Pages filed by Cisco Systems, Inc.. (Kramer, Karin) (Filed on 7/22/2011) Modified on 7/22/2011 (feriab, COURT STAFF).

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Kathleen M. Sullivan (CA Bar No. 242261)  kathleensullivan@quinnemanuel.com 555 Twin Dolphin Drive, 5th Floor  Redwood City, California 94065 (650) 801-5000  Telephone: Facsimile: (650) 801-5100  Faith E. Gay (pro hac vice)  faithgay@quinnemanuel.com Isaac Nesser (pro hac vice)  isaacnesser@quinnemanuel.com  51 Madison Avenue, 22nd Floor New York, New York 10010  Telephone: (212) 849-7000 Facsimile: (212) 849-7100  Attorneys for Defendants Cisco Systems, Inc.,  John Chambers, Thomas Lam, and Owen Chan   UNITED STATES DISTRICT COURT  NORTHERN DISTRICT OF CALIFORNIA  SAN JOSE DIVISION   Doe I, Doe II, Ivy He, Doe III, Doe IV, Doe V,  Doe VI, ROE VII, Charles Lee, Roe VIII, Liu Guifu, and those individuals similarly situated,  Plaintiffs,   Case No. 5:11-cv-02449-JF-PSG JOINT ADMINISTRATIVE MOTION TO EXCEED APPLICABLE PAGE LIMIT v.  Cisco Systems, Inc., John Chambers, Thomas Lam, Owen Chan, and Does 1-100,  Defendants.       Case No. 5:11-cv-02449-JF-PSG Joint Administrative Motion to Exceed Applicable Page Limit 1 Plaintiffs and Defendants jointly move the Court pursuant to Local Rule 7-11 for an order 2 extending the applicable page limits for briefs that will be filed in connection with Defendants’ 3 forthcoming Motion to Dismiss the Complaint. 4 Defendants’ Motion to Dismiss the Complaint is scheduled to be filed on August 4, 2011. 5 Plaintiffs’ Class Action Complaint is 52 pages long and asserts fourteen causes of action. The 6 Complaint asserts claims under international law, U.S. statutory law, and California law, including 7 pursuant to the Alien Tort Statute and Torture Victim Protection Act; alleges acts taken in China; 8 asserts claims on behalf of ten Plaintiffs; and asserts claims against four Defendants. 9 Defendants requested that Plaintiffs consent to a request to the Court for an extension of 10 the applicable 25-page limit to 50 pages for their brief in support of the Motion to Dismiss. As a 11 professional courtesy, Plaintiffs agreed not to oppose such a request, on the condition that, in the 12 event the Court is inclined to grant such request, the Defendants reciprocally agree to not oppose 13 Plaintiffs’ request for a reciprocal extension of pages for the opposition brief to Defendants’ 14 Motion to Dismiss the Complaint. The parties further agreed that Plaintiffs would not oppose a 15 Request for an extension of the applicable 15-page limit for Defendants’ reply brief in support of 16 their forthcoming Motion to Dismiss the Complaint. 17 Accordingly, the parties join in this Motion for an order granting the following: 18 1. Defendants’ opening brief in support of their Motion to Dismiss the Complaint, and 19 Plaintiffs’ brief in opposition that Motion, may each be a maximum of 50 pages of text, excluding 20 tables of contents, tables of authorities, and supporting documents. 21 2. Defendants’ reply brief in further support of their Motion to Dismiss the Complaint 22 may be a maximum of 20 pages of text, excluding tables of contents, tables of authorities, and 23 supporting documents. 24 A stipulation and proposed order is attached to this Joint Motion. 25 26 27 28 Case No. 5:11-cv-02449-JF-PSG Joint Administrative Motion to Exceed Applicable Page Limit -2- 1 2 DATED: July 22, 2011 3 QUINN EMANUEL URQUHART & SULLIVAN, LLP By /s/ Kathleen M. Sullivan Kathleen M. Sullivan kathleensullivan@quinnemanuel.com Faith E. Gay faithgay@quinnemanuel.com Isaac Nesser isaacnesser@quinnemanuel.com 4 5 6 7 Attorneys for Defendants 8 9 SCHWARCZ RIMBERG BOYD & RADER, LLP 10 By /s/ K. Kee Boyd K. Kee Boyd* lboyd@srbr-law.com 11 12 Attorneys for Plaintiffs 13 14 HUMAN RIGHTS LAW FOUNDATION 15 By /s/ Terri M. Marsh Terri M. Marsh* terri.marsh@hrlf.net 16 17 Attorneys for Plaintiffs 18 19 20 21 22 23 24 25 26 27 * 28 I have obtained signatory's consent to file this stipulation and proposed order. Case No. 5:11-cv-02449-JF-PSG Joint Administrative Motion to Exceed Applicable Page Limit -3-