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

Filing 59

STIPULATION and [Proposed] Order Re: Extending Plaintiffs' Time to File a First Amended Complaint Pursuant to Fed. R. Civ. P. Rule 15(a)(1)(B) 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 8/24/2011)

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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,
Defendants.

STIPULATION AND [PROPOSED]
ORDER RE: EXTENDING PLAINTIFFS’
TIME TO FILE A FIRST AMENDED
COMPLAINT PURSUANT TO FED. R.
CIV. P. RULE 15(a)(1)(B)
Action Filed: May 19, 2011
Scheduling Conference: September 23, 2011
Time: 10:30 am
Courtroom: 3, 5th floor

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STIPULATION AND [PROPOSED] ORDER RE: EXTENDING PLAINTIFFS’
TIME TO FILE A FAC PURSUANT TO FED. R. CIV. P. RULE 15(a)(1)(B)
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”) (“Defendants”) (collectively, the “Parties”), as

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follows:
WHEREAS, pursuant to the stipulation of the Parties, Defendants’ Motion to Dismiss

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was due no later than August 4, 2011 (docket entry “DE” 25);
WHEREAS, Defendants filed their Motion to Dismiss on August 4, 2011 (DE 49);

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WHEREAS, the Parties held a telephonic conference pursuant to Fed. R. Civ. P. Rule

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26(f) on August 5, 2011, in which Plaintiffs notified Defendants that they expected to file a First

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Amended Complaint as a matter of course pursuant to Fed. R. Civ. P. Rule 15(a)(1)(B) by August

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25, 2011;
WHEREAS, on Sunday, August 14, 2011, Terri Marsh, lead counsel for Plaintiffs, was

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

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contusions, and minor cuts and bruises, and has been unable to return to work and address the

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expected amendments to the Complaint;

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WHEREAS, on August 22, 2011, Terri Marsh emailed Kathleen Sullivan, lead counsel

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for Defendants, and requested that, on account of the extenuating circumstances relating to her

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car accident, Plaintiffs be given additional time to file their expected First Amended Complaint as

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a matter of course pursuant to Fed. R. Civ. P. Rule 15(a)(1)(B); and
WHEREAS, Kathleen Sullivan agreed to extend Plaintiffs’ time to file their expected

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First Amended Complaint from August 25, 2011, by seven (7) to ten (10) days.

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-1STIPULATION AND [PROPOSED] ORDER RE: EXTENDING PLAINTIFFS’
TIME TO FILE A FAC PURSUANT TO FED. R. CIV. P. RULE 15(a)(1)(B)
Case No. 5:11-cv-02449-JF-PSG

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

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through their respective counsel, that if Plaintiffs file a First Amended Complaint as a matter of

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course pursuant to Fed. R. Civ. P. Rule 15(a)(1)(B), such First Amended Complaint shall be filed

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on or before September 2, 2011.

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DATED: August 24, 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 24, 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 24, 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 RE: EXTENDING PLAINTIFFS’
TIME TO FILE A FAC PURSUANT TO FED. R. CIV. P. RULE 15(a)(1)(B)
Case No. 5:11-cv-02449-JF-PSG