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

Filing 73

STIPULATION and [Proposed] Order RE: BRIEFING SCHEDULE FOR 67 MOTION TO DISMISS 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 Declaration of Kristen Nelson ISO (Boyd, Kathryn) (Filed on 10/10/2011) Modified on 10/13/2011,(link to motion.) (cv, COURT STAFF).

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1 2 3 4 5 6 7 8 9 10 11 12 13 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 JUDITH BROWN CHOMSKY (pro hac vice) 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 Attorneys for PLAINTIFFS 14 15 UNITED STATES DISTRICT COURT FOR THE 16 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION Case No. 5:11-cv-02449-EJD DOE I, DOE II, Ivy HE, DOE III, DOE IV, DOE V, DOE VI, ROE VII, Charles LEE, Assigned to the Honorable Edward J. Davila ROE VIII, and LIU Guifu, STIPULATION AND [PROPOSED] Plaintiffs, ORDER RE: BRIEFING SCHEDULE FOR vs. MOTION TO DISMISS CISCO SYSTEMS, INC., John CHAMBERS, Thomas LAM, Owen CHAN, Fredy Action Filed: May 19, 2011 FAC Filed: September 2, 2011 CHEUNG, and DOES 1-100, 17 18 19 20 21 22 23 24 Defendants. Hearing: February 17, 2012 Time: 9:00 am Courtroom: 1, 5th floor 25 26 27 28 STIPULATION AND [PROPOSED] ORDER RE: BRIEFING SCHEDULE FOR MOTION TO DISMISS Case No. 5:11-cv-02449-EJD STIPULATION 1 2 IT IS HEREBY STIPULATED AND AGREED between DOE I, DOE II, Ivy HE, DOE 3 III, DOE IV, DOE V, DOE VI, ROE VII, Charles LEE, ROE VIII, and LIU Guifu (“Plaintiffs”) 4 and Defendants CISCO SYSTEMS, INC. (“Cisco”), John CHAMBERS (“Chambers”), Thomas 5 LAM (“Lam”), Owen CHAN (“Chan”), and Fredy CHEUNG (“Cheung”) (“Defendants”) 6 (collectively, the “Parties”), as follows: WHEREAS, pursuant to Fed. R. Civ. P. 15(a)(1)(B) and by stipulation, Plaintiffs filed a 7 8 Corrected First Amended Complaint (“FAC”) on September 2, 2011 (Docket Entry (“DE”) 62-1); WHEREAS, on September 23, 2011, Defendants filed a Motion to Dismiss the FAC 9 10 (“Motion to Dismiss”) (DE 67); WHEREAS, pursuant to discussions between counsel, the Parties agreed to extend the 11 12 briefing schedule on the Motion to Dismiss; WHEREAS, in mid-August 2011, Terri Marsh, lead trial counsel for Plaintiffs, was 13 14 involved in a head-on automobile collision and suffered injuries including whiplash, facial 15 contusions, and minor cuts and bruises, took a one-month leave of absence from work, and has 16 been ordered by her doctor to work only part-time through the remainder of the year for medical 17 reasons, and Plaintiffs accordingly requested that their Opposition be due on November 18, 2011; WHEREAS, counsel for Defendants have scheduling conflicts between mid-November 18 19 and mid-December 2011, and Defendants accordingly requested that their Reply be due on 20 January 16, 2012; 21 WHEREAS, the Motion to Dismiss will be fully briefed by mid-January 2012; 22 NOW THEREFOR IT IS HEREBY STIPULATED, by and between the Parties, 23 through their respective counsel, subject to and in accordance with the recitations set forth above, 24 that: 25 26 1. Plaintiffs’ Opposition to the Motion to Dismiss and any and all supporting documents are due no later than November 18, 2011; Defendants’ Reply and any and all supporting documents are due no later than 27 2. 28 January 16, 2012; -1STIPULATION AND [PROPOSED] ORDER RE: BRIEFING SCHEDULE FOR MOTION TO DISMISS Case No. 5:11-cv-02449-EJD 3. 1 The Motion to Dismiss is scheduled to be heard at 9:00am on February 17, 2010, 2 in Courtroom 1, 5th Floor, of the above-referenced Court.1 3 DATED: October 10, 2011 4 5 SCHWARCZ, RIMBERG, BOYD & RADER, LLP By: 6 7 DATED: October 10, 2011 /s/ K. Lee Boyd K. Lee Boyd, Esq. HUMAN RIGHTS LAW FOUNDATION 8 By: 9 10 DATED: October 10, 2011 /s/ Terri E. Marsh Terri E. Marsh, Esq. (pro hac vice) LAW OFFICES OF JUDITH BROWN CHOMSKY 11 12 By: 13 Attorneys for Plaintiffs 14 15 /s/ Judith B. Chomsky Judith B. Chomsky, Esq. (pro hac vice) DATED: October 10, 2011 QUINN EMANUEL URQUHART & SULLIVAN, LLP 16 17 By: 18 19 /s/ Kathleen Sullivan Kathleen Sullivan, Esq.2 Isaac Nesser, Esq. Attorneys for Defendants 20 21 22 PURSUANT TO STIPULATION, IT IS SO ORDERED. 23 24 DATED:_________________, 2011 25 ________________________________ Hon. Edward J. Davila United States District Judge 26 27 28 1 Pursuant to the Hon. Edward J. Davila’s Scheduling Notes, on October 6, 2011, counsel for Plaintiffs tentatively reserved a hearing date of February 17, 2011, for the Motion to Dismiss. 2 I have given my consent for Plaintiffs to electronically sign this Stipulation on my behalf. -2STIPULATION AND [PROPOSED] ORDER RE: BRIEFING SCHEDULE FOR MOTION TO DISMISS Case No. 5:11-cv-02449-EJD