Xiaoning et al v. Yahoo! Inc, et al

Filing 43

Declaration of Morton Sklar, Matthew T. Kline, and Scott Reynolds in Support of 42 Stipulation, Re: Withdrawal of the Plaintiffs' Motion for Leave to File Second Amended Complaint, Re: Filing of Second Amended Complaint, and Re: Extending Time Deadlines Accordingly filed byYahoo! Inc.. (Related document(s) 42 ) (Petrocelli, Daniel) (Filed on 7/19/2007)

Xiaoning et al v. Yahoo! Inc, et al

Doc. 43

Case 4:07-cv-02151-CW

Document 43

Filed 07/19/2007

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MORTON H. SKLAR (admitted pro hac vice) [e-mail] WORLD ORGANIZATION FOR HUMAN RIGHTS USA 2029 P Street NW, Suite 301 Washington, DC 20036 Telephone: [phone] Facsimile: [phone] [Local Counsel, Roger R. Myers of Holme Roberts & Owen LLP, Listed on the Signature Page] Attorneys for Plaintiffs DANIEL PETROCELLI (S.B. #97802) [e-mail] O'MELVENY & MYERS LLP 1999 Avenue Of The Stars Los Angeles, California 90067-6035 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant YAHOO!, INC. JOSEPH P. CYR (pro hac vice application forthcoming) [e-mail] SCOTT REYNOLDS (pro hac vice application forthcoming) [e-mail] LOVELLS LLP 590 Madison Ave. New York, New York 10022 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant ALIBABA.COM, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION WANG XIAONING, YU LING, SHI TAO, and ADDITIONAL PRESENTLY UNNAMED AND TO BE IDENTIFIED INDIVIDUALS, Plaintiffs, v. YAHOO! INC., a Delaware Corporation, YAHOO! HONG KONG, LTD., a Foreign Subsidiary of Yahoo!, ALIBABA.COM INC., a Delaware Corporation AND OTHER PRESENTLY UNNAMED AND TO BE IDENTIFIED CORPORATE DEFENDANTS AND UNNAMED AND TO BE IDENTIFIED INDIVIDUAL EMPLOYEES OF SAID CORPORATIONS, Defendants.

CASE NO. C07-02151 CW JOINT DECLARATION OF MORTON SKLAR, MATTHEW T. KLINE, AND SCOTT REYNOLDS IN SUPPORT OF JOINT STIPULATION RE: WITHDRAWAL OF THE PLAINTIFFS' MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT, RE: FILING OF SECOND AMENDED COMPLAINT, AND RE: EXTENDING TIME DEADLINES ACCORDINGLY

Joint Declaration in support of Joint Stipulation
#29504 v1

Case No. C 07-02151 CW

Dockets.Justia.com

Case 4:07-cv-02151-CW

Document 43

Filed 07/19/2007

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We--Morton Sklar, Executive Director of the World Organization for Human Rights USA, representing the Plaintiffs; Matthew Kline for the law firm of O'Melveny and Myers LLP, representing Defendant Yahoo!, Inc.; and Scott Reynolds of the law firm of Lovells LLP, representing Defendant Alibaba.com, Inc.--hereby declare as follows: 1. On July 13, 2007, plaintiffs filed a Motion for Leave of the Court to File a Second Amended Complaint. In the days following, defendants lodged objections to both the motion and proposed amended complaint. Defendants also voiced concerns about the motion's impact on the schedule in the case. 2. Yesterday morning, the parties had a productive discussion regarding Plaintiffs' pending motion and schedule in the case. In order to save the Court's and parties' resources, and in order to make sure that there is a final amended complaint to which defendants can soon respond, Defendants and Plaintiffs agreed to the Stipulation being filed herewith and agreed to continue to work together to make sure that this case is resolved expeditiously. 3. Rather than repeat the terms of the stipulation, we hereby incorporate them herein by reference, including the description of the relief being sought, the need for this relief, and the impact of this relief on the current schedule. We declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed in Washington, D.C. (Morton Sklar), Los Angeles, California (Matthew T. Kline), and New York, New York (Scott Reynolds) on this 19th day of July 2007. By: /s/ Morton Sklar Morton Sklar By: /s/ Matthew Kline Matthew T. Kline By: /s/ Scott Reynolds Scott Reynolds

CC1:767279.1

2 Joint Declaration in support of Joint Stipulation
#29504 v1

Case No. C07-02151 CW