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

Filing 47

STIPULATION AND ORDER TO EXCEED APPLICABLE PAGE LIMIT (granting 43 ). (jflc2, COURT STAFF) (Filed on 7/28/2011)

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


**E-Filed 7/28/2011**




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
STIPULATION AND -----------------[PROPOSED]
ORDER 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
Stipulation and [Proposed] Order to Exceed Applicable Page Limit

1

WHEREAS, Defendants’ Motion to Dismiss the Complaint is scheduled to be filed on

2 August 4, 2011;
3

WHEREAS, Plaintiffs’ Class Action Complaint is 52 pages long and asserts fourteen

4 causes of action;
5

WHEREAS, the Plaintiffs and Defendants agree that the applicable 25-page limit for

6 briefs in support of and in opposition to Defendants’ forthcoming Motion to Dismiss the
7 Complaint is insufficient to address the claims and issues raised in the Complaint; and
8

WHEREAS, the Plaintiffs and Defendants further agree that the applicable 15-page limit

9 for Defendants’ reply brief in support of their forthcoming Motion to Dismiss the Complaint is
10 insufficient to address the claims and issues raised in the Complaint; and
11

WHEREAS, the Plaintiffs and Defendants further agree that extending the page limit will

12 allow the parties to address adequately each claim and issue, and assist the Court in efficiently and
13 effectively resolving Defendants’ forthcoming Motion to Dismiss the Complaint;
14

NOW, THEREFORE, the Parties stipulate as follows:

15

1.

Defendants’ opening brief in support of their Motion to Dismiss the Complaint, and

16 Plaintiffs’ brief in opposition that Motion, may each be a maximum of 50 pages of text, excluding
17 tables of contents, tables of authorities, and supporting documents.
18

2.

Defendants’ reply brief in further support of their Motion to Dismiss the Complaint

19 may be a maximum of 20 pages of text, excluding tables of contents, tables of authorities, and
20 supporting documents.
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Case No. 5:11-cv-02449-JF-PSG
Stipulation and [Proposed] Order to Exceed Applicable Page Limit

1
2

DATED: July 22, 2011

QUINN EMANUEL URQUHART &
SULLIVAN, LLP

3

By /s/ Kathleen M. Sullivan
Kathleen M. Sullivan
[e-mail]
Faith E. Gay
[e-mail]
Isaac Nesser
[e-mail]

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Attorneys for Defendants

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SCHWARCZ RIMBERG BOYD & RADER, LLP

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

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Attorneys for Plaintiffs
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HUMAN RIGHTS LAW FOUNDATION

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

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Attorneys for Plaintiffs

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

22

DATED:

July 28

, 2011

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24

Hon. Jeremy Fogel

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*

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I have obtained signatory's consent to file this stipulation and proposed order.
Case No. 5:11-cv-02449-JF-PSG
Stipulation and [Proposed] Order to Exceed Applicable Page Limit