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)
 [e-mail]
555 Twin Dolphin Drive, 5th Floor
 Redwood City, California 94065
[phone]
 Telephone:
Facsimile:
[phone]

Faith E. Gay (pro hac vice)
 [e-mail]
Isaac Nesser (pro hac vice)

[e-mail]
 51 Madison Avenue, 22nd Floor
New York, New York 10010
 Telephone:
[phone]
Facsimile:
[phone]

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.

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Case No. 5:11-cv-02449-JF-PSG
Joint Administrative Motion to Exceed Applicable Page Limit

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1
2

DATED: July 22, 2011

3

QUINN EMANUEL URQUHART &
SULLIVAN, LLP
By /s/ Kathleen M. Sullivan
Kathleen M. Sullivan
[e-mail]
Faith E. Gay
[e-mail]
Isaac Nesser
[e-mail]

4
5
6
7

Attorneys for Defendants

8
9

SCHWARCZ RIMBERG BOYD & RADER, LLP

10

By /s/ K. Kee Boyd
K. Kee Boyd*
[e-mail]

11
12

Attorneys for Plaintiffs
13
14

HUMAN RIGHTS LAW FOUNDATION

15

By /s/ Terri M. Marsh
Terri M. Marsh*
[e-mail]

16
17

Attorneys for Plaintiffs

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19
20
21
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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

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