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

Filing 52

NOTICE by John Chambers, Owen Chan, Cisco Systems, Inc., Thomas Lam Rule 44.1 Notice of Intent to Raise Issue of Foreign Law on Motion to Dismiss (Sullivan, Kathleen) (Filed on 8/4/2011)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Kathleen M. Sullivan (CA Bar No. 242261)
2
[e-mail]
555 Twin Dolphin Drive, 5th Floor
3 Redwood City, California 94065
Telephone:
[phone]
4 Facsimile:
[phone]
5

Faith E. Gay (pro hac vice)
[e-mail]
6
Isaac Nesser (pro hac vice)
[e-mail]
7 51 Madison Avenue, 22nd Floor
New York, New York 10010
8 Telephone:
[phone]
Facsimile:
[phone]
9
Attorneys for Defendants Cisco Systems, Inc.,
10 John Chambers, Thomas Lam, and Owen Chan
11
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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14 Doe I, Doe II, Ivy He, Doe III, Doe IV, Doe V,
Doe VI, Roe VII, Charles Lee, Roe VIII, Liu
15 Guifu, and those individuals similarly situated,
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Plaintiffs,
v.

Case No. 5:11-cv-02449-JF
DEFENDANTS’ RULE 44.1 NOTICE OF
INTENT TO RAISE ISSUE OF FOREIGN
LAW ON MOTION TO DISMISS
Hearing date: December 16, 2011
Time: 10:00 a.m.

18 Cisco Systems, Inc., John Chambers, Thomas
Lam, Owen Chan, and Does 1-100,
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Defendants.
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Action Filed: May 19, 2011
Judge: Hon. Jeremy Fogel
Dept: Courtroom 3, 5th Floor

21 TO THE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE that pursuant to Rule 44.1 of the Federal Rules of Civil

23 Procedure, defendants Cisco Systems, Inc., John Chambers, Thomas Lam, and Owen Chan
24 (collectively, “Defendants”) hereby give notice of their intent to raise issues of Chinese law that
25 may arise in connection with Defendants’ motion to dismiss the complaint. Pursuant to Rule 44.1
26 and to assist the Court, Defendants will submit the Declaration of John Chu, a licensed attorney
27 authorized and engaged in the practice of law in the People’s Republic of China, and a partner at
28 the Jun He Law Offices in China.
Case No. :11-cv-02449-JF
DEFENDANTS' NOTICE OF INTENT TO RAISE ISSUE OF FOREIGN LAW

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The Motion is scheduled to be heard on or after December 16, 2011.

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DATED:
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New York, New York
August 4, 2011
QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By: /s/ Kathleen M. Sullivan
Kathleen M. Sullivan
Faith E. Gay
Isaac Nesser

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51 Madison Avenue, 22d Floor
New York, New York 10010-1601
[phone]
Attorneys for Defendants

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Case No. :11-cv-02449-JF
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DEFENDANTS’ NOTICE OF INTENT TO RAISE ISSUE OF FOREIGN LAW

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CERTIFICATE OF SERVICE

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The undersigned hereby certifies that all counsel of record who are deemed to

3 have consented to electronic service are being served with a copy of this document via
4 the Court’s ECF System.
5 Dated: August 4, 2011
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/s/ Arthur Roberts
Arthur Roberts

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Case No. :11-cv-02449-JF
DEFENDANTS’ NOTICE OF INTENT TO RAISE ISSUE OF FOREIGN LAW