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

Filing 62

ERRATA to 61 First Amended Complaint by Doe I, Doe II, Doe III, Doe IV, Doe V, Doe VI, Liu Guifu, Ivy He, Charles Lee, Roe VII, Roe VIII. (Attachments: # 1 Corrected First Amended Complaint)(Boyd, Kathryn) (Filed on 9/2/2011) Modified on 9/7/2011 (gm, COURT STAFF).

1 2 3 4 5 6 7 8 9 KATHRYN LEE CRAWFORD-BOYD, ESQ. (SBN 189496) lboyd@srbr-law.com RAJIKA L. SHAH, ESQ. (SBN 232994) rshah@srbr-law.com SCHWARCZ, RIMBERG, BOYD & RADER, LLP 6310 San Vicente Boulevard, Suite 360 Los Angeles, California 90048 Phone: (323) 302-9488, Fax: (323) 931-4990 TERRI MARSH, ESQ. (pro hac vice) terri.marsh@hrlf.net BRIAN PIERCE, ESQ. (pro hac vice) brianp@hrlf.net HUMAN RIGHTS LAW FOUNDATION 1615 L Street NW, Suite 1100 Washington, D.C. 20036 Phone: (202) 369-4977, Fax: (323) 931-4990 12 JUDITH BROWN CHOMSKY (pro hac vice pending) jchomsky@igc.org LAW OFFICES OF JUDITH BROWN CHOMSKY 8210 New Second Street Elkins Park, PA 19027 Phone: (215) 782-8327, Fax: (215)782-8368 13 Attorneys for PLAINTIFFS 10 11 14 15 16 17 UNITED STATES DISTRICT COURT FOR THE 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, and LIU Guifu, and those individual similarly situated, 18 19 20 Plaintiffs, Case No. 5:11-cv-02449-JF-PSGx Assigned to the Hon. Jeremy Fogel NOTICE OF ERRATA RE: FIRST AMENDED CLASS ACTION COMPLAINT vs. 21 22 23 CISCO SYSTEMS, INC., John CHAMBERS, Thomas LAM, Owen CHAN, Fredy CHEUNG, and DOES 1100, 24 25 Defendants. 26 27 28 SCHWARCZ, RIMBERG, BOYD & RADER, LLP 6310 San Vicente Blvd Los Angeles, CA 90048 NOTICE OF ERRATA RE: FIRST AMENDED COMPLAINT Case No. 5:11-cv-02449-JF-PSGx 1 2 3 TO THE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Please take notice that counsel for Plaintiffs DOE I, DOE II, Ivy HE, DOE III, 4 DOE IV, DOE V, DOE VI, ROE VII, Charles LEE, ROE VIII, and LIU Guifu 5 (collectively, “Plaintiffs”) inadvertently uploaded the incorrect file, containing an earlier 6 draft, when e-filing the First Amended Complaint (“FAC”) on September 2, 2011 (Docket 7 Entry 61). The correct file with the final version of the First Amended Complaint will be 8 uploaded hereafter and titled “Corrected First Amended Complaint.” 9 10 The three paragraphs where there are differences between the erroneously uploaded document (FAC) and the correct document (Corrected FAC) are as follows: 11 FAC ¶ 147: 12 During their interrogation of Doe II, the police subjected her to severe mental and 13 physical abuse, so much so that she falsely confessed to crimes she subsequently denied at 14 her trial. 15 CORRECTED ¶ 147: 16 During the interrogation of Doe II, the police subjected her to severe mental and 17 physical abuse, so much so that she characterized as "criminal" acts that are perfectly 18 legal under Chinese and international law. 19 FAC ¶ 158: 20 At the police station, Public Security officers interrogated her continuously for 21 many hours in order to force her to falsely confess to crimes she believed she did not 22 commit. They poured ice-cold water over her naked body and forced her to stand in a 23 bucket of ice. She was also kicked, beaten, insulted and subjected continuously to other 24 forms public humiliation, and mental and physical torture. 25 CORRECTED ¶ 158: 26 At the police station, Public Security officers interrogated her continuously for 27 many hours in order to force her to characterize acts that are perfectly legal under 28 Chinese and international law as "crimes." They poured ice-cold water over her naked 1 SCHWARCZ, RIMBERG, BOYD & RADER, LLP 6310 San Vicente Blvd Los Angeles, CA 90048 NOTICE OF ERRATA RE: FIRST AMENDED COMPLAINT Case No. 5:11-cv-02449-JF-PSGx 1 body and forced her to stand in a bucket of ice. She was also kicked, beaten, insulted and 2 subjected continuously to other forms public humiliation, and mental and physical torture. 3 FAC ¶ 194: 4 The next day, Public Security officers took Doe VI to Weifang City detention 5 center. While at the detention center, he was subjected to continuous interrogation and 6 torture to force him to falsely confess to criminal conduct and to abandon the practice of 7 Falun Gong. He was not formally charged until almost a month later. 8 CORRECTED ¶ 194: 9 The next day, Public Security officers took Doe VI to Weifang City detention 10 center. While at the detention center, he was subjected to continuous interrogation and 11 other forms of torture to force him to characterize activities that are legal under Chinese 12 and international law as "crimes" and to abandon the practice of Falun Gong. He was not 13 formally charged until almost a month later. 14 15 DATED: September 2, 2011 Respectfully submitted, 16 SCHWARCZ, RIMBERG, BOYD & RADER, LLP 17 18 19 20 21 22 By: /s/ K. Lee Crawford-Boyd K. Lee Crawford-Boyd, Esq. Attorney for Plaintiffs Terri E. Marsh, Esq. HUMAN RIGHTS LEGAL FOUNDATION Attorney for Plaintiffs 23 24 25 26 Judith Brown Chomsky, Esq. LAW OFFICES OF JUDITH BROWN CHOMSKY To be admitted pro hac vice Attorney for Plaintiffs 27 28 2 SCHWARCZ, RIMBERG, BOYD & RADER, LLP 6310 San Vicente Blvd Los Angeles, CA 90048 NOTICE OF ERRATA RE: FIRST AMENDED COMPLAINT Case No. 5:11-cv-02449-JF-PSGx