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

Filing 57

STIPULATION Re: Rescheduling August 26, 2011 Case Management Conference by Doe I, Doe II, Doe III, Doe IV, Doe V, Doe VI, Liu Guifu, Ivy He, Charles Lee, Roe VII, Roe VIII. (Boyd, Kathryn) (Filed on 8/19/2011)

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KATHRYN LEE BOYD, ESQ. (SBN 189496)
[e-mail]
RAJIKA L. SHAH, ESQ. (SBN 232994)
[e-mail]
SCHWARCZ, RIMBERG, BOYD & RADER, LLP
6310 San Vicente Boulevard, Suite 360
Los Angeles, California 90048
Phone: [phone]
Fax: [phone]
TERRI MARSH, ESQ. (pro hac vice)
[e-mail]
BRIAN PIERCE, ESQ. (pro hac vice)
[e-mail]
HUMAN RIGHTS LAW FOUNDATION
1615 L Street NW, Suite 1100
Washington, D.C. 20036
Phone: [phone]
Fax: [phone]

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Attorneys for PLAINTIFFS
UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
Case No. 5:11-cv-02449-JF-PSG
DOE I, DOE II, Ivy HE, DOE III, DOE IV,
DOE V, DOE VI, ROE VII, Charles LEE,
Assigned to the Honorable Jeremy Fogel,
ROE VIII, and LIU Guifu,
U.S.D.J.

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Plaintiffs,
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vs.
CISCO SYSTEMS, INC., John CHAMBERS,
Thomas LAM, Owen CHAN, and DOES 1100,

STIPULATION AND [PROPOSED]
ORDER RESCHEDULING AUGUST 26,
2011, CASE MANAGEMENT
CONFERENCE
Action Filed: May 19, 2011

Defendants.
Scheduling Conference: August 26, 2011
Time: 10:30 am
Courtroom: 3, 5th floor

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STIPULATION AND [PROPOSED] ORDER RESCHEDULING AUGUST 26, 2011, CASE MANAGEMENT CONFERENCE
Case No. 5:11-cv-02449-JF-PSG

STIPULATION

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IT IS HEREBY STIPULATED AND AGREED between DOE I, DOE II, Ivy HE, DOE

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III, DOE IV, DOE V, DOE VI, ROE VII, Charles LEE, ROE VIII, and LIU Guifu (“Plaintiffs”)

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and Defendants CISCO SYSTEMS, INC. (“Cisco”), John CHAMBERS (“Chambers”), Thomas

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LAM (“Lam”), and Owen CHAN (“Chan”) (collectively, the “Parties”), as follows:
WHEREAS, following the stipulation of the Parties, the Court ordered that the Case

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Management Conference be held on August 26, 2011 at 10:30 am (docket entry 44);
WHEREAS, the Parties held a telephonic conference pursuant to Fed. R. Civ. P. Rule

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26(f) on August 5, 2011;

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WHEREAS, the Parties participated in drafting a Joint Case Management Statement;

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WHEREAS, on Sunday, August 14, 2011, Terri Marsh, lead trial counsel for Plaintiffs,

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was involved in a head-on automobile collision and suffered injuries including whiplash, facial

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contusions, and minor cuts and bruises, and will be unable to travel to San Jose to appear

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personally at the Case Management Conference on August 26;
WHEREAS, Ms. Marsh would like to appear before the Court in person prior to

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reassignment of the case due to Judge Fogel’s appointment to the Federal Judicial Center in

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Washington, D.C.;

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WHEREAS, Ms. Marsh expects to be able to travel within three to four weeks;

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NOW THEREFOR IT IS HEREBY STIPULATED, by and between the Parties,

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through their respective counsel, that:
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The August 12 Case Management Conference shall be adjourned and rescheduled

to September 23, 2011 at 10:30 am, in Courtroom 3, 5th Floor, at the San Jose Courthouse.
2.

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The Joint Case Management Statement shall be submitted to the Court no later

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than September 16, 2011.

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///

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///

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///

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-1STIPULATION AND [PROPOSED] ORDER RESCHEDULING AUGUST 26, 2011, CASE MANAGEMENT CONFERENCE
Case No. 5:11-cv-02449-JF-PSG

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DATED: August 19, 2011

SCHWARCZ, RIMBERG, BOYD &
RADER, LLP

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By:

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/s/ K. Lee Boyd
K. Lee Boyd, Esq.

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HUMAN RIGHTS LAW FOUNDATION
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DATED: August 19, 2011

By:

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/s/ Terri Marsh
Terri E. Marsh, Esq. (pro hac vice)

Attorneys for Plaintiffs

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DATED: August 19, 2011

QUINN EMANUEL URQUHART
& SULLIVAN, LLP

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By:

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/s/ Kathleen Sullivan
Kathleen Sullivan, Esq.1
Isaac Nesser, Esq.

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Attorneys for Defendants

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED:

, 2011

_________________________________________
Hon. Jeremy Fogel

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I have given my consent for Plaintiffs to electronically sign this Stipulation on my behalf.
-2STIPULATION AND [PROPOSED] ORDER RESCHEDULING AUGUST 26, 2011, CASE MANAGEMENT CONFERENCE
Case No. 5:11-cv-02449-JF-PSG