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

Filing 62

ERRATA to 61 First Amended Complaint by Doe I, Doe II, Doe III, Doe IV, Doe V, Doe VI, Liu Guifu, Ivy He, Charles Lee, Roe VII, Roe VIII. (Attachments: # 1 Corrected First Amended Complaint)(Boyd, Kathryn) (Filed on 9/2/2011) Modified on 9/7/2011 (gm, COURT STAFF).

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KATHRYN LEE CRAWFORD-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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JUDITH BROWN CHOMSKY (pro hac vice pending)
[e-mail]
LAW OFFICES OF JUDITH BROWN CHOMSKY
8210 New Second Street
Elkins Park, PA 19027
Phone: [phone], Fax: [phone]

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Attorneys for PLAINTIFFS

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UNITED STATES DISTRICT COURT FOR THE
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, and LIU Guifu, and
those individual similarly situated,

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Plaintiffs,

Case No. 5:11-cv-02449-JF-PSGx
Assigned to the Hon. Jeremy Fogel
NOTICE OF ERRATA RE: FIRST
AMENDED CLASS ACTION
COMPLAINT

vs.

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CISCO SYSTEMS, INC., John
CHAMBERS, Thomas LAM, Owen
CHAN, Fredy CHEUNG, and DOES 1100,

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Defendants.

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SCHWARCZ, RIMBERG,
BOYD & RADER, LLP
6310 San Vicente Blvd
Los Angeles, CA 90048

NOTICE OF ERRATA RE: FIRST AMENDED COMPLAINT
Case No. 5:11-cv-02449-JF-PSGx

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TO THE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF
RECORD:
Please take notice that counsel for Plaintiffs DOE I, DOE II, Ivy HE, DOE III,

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DOE IV, DOE V, DOE VI, ROE VII, Charles LEE, ROE VIII, and LIU Guifu

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(collectively, “Plaintiffs”) inadvertently uploaded the incorrect file, containing an earlier

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draft, when e-filing the First Amended Complaint (“FAC”) on September 2, 2011 (Docket

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Entry 61). The correct file with the final version of the First Amended Complaint will be

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uploaded hereafter and titled “Corrected First Amended Complaint.”

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The three paragraphs where there are differences between the erroneously uploaded
document (FAC) and the correct document (Corrected FAC) are as follows:

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FAC ¶ 147:

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During their interrogation of Doe II, the police subjected her to severe mental and

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physical abuse, so much so that she falsely confessed to crimes she subsequently denied at

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her trial.

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CORRECTED ¶ 147:

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During the interrogation of Doe II, the police subjected her to severe mental and

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physical abuse, so much so that she characterized as "criminal" acts that are perfectly

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legal under Chinese and international law.

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FAC ¶ 158:

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At the police station, Public Security officers interrogated her continuously for

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many hours in order to force her to falsely confess to crimes she believed she did not

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commit. They poured ice-cold water over her naked body and forced her to stand in a

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bucket of ice. She was also kicked, beaten, insulted and subjected continuously to other

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forms public humiliation, and mental and physical torture.

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CORRECTED ¶ 158:

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At the police station, Public Security officers interrogated her continuously for

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many hours in order to force her to characterize acts that are perfectly legal under

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Chinese and international law as "crimes." They poured ice-cold water over her naked
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SCHWARCZ, RIMBERG,
BOYD & RADER, LLP
6310 San Vicente Blvd
Los Angeles, CA 90048

NOTICE OF ERRATA RE: FIRST AMENDED COMPLAINT
Case No. 5:11-cv-02449-JF-PSGx

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body and forced her to stand in a bucket of ice. She was also kicked, beaten, insulted and

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subjected continuously to other forms public humiliation, and mental and physical torture.

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FAC ¶ 194:

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The next day, Public Security officers took Doe VI to Weifang City detention

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center. While at the detention center, he was subjected to continuous interrogation and

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torture to force him to falsely confess to criminal conduct and to abandon the practice of

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Falun Gong. He was not formally charged until almost a month later.

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CORRECTED ¶ 194:

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The next day, Public Security officers took Doe VI to Weifang City detention

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center. While at the detention center, he was subjected to continuous interrogation and

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other forms of torture to force him to characterize activities that are legal under Chinese

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and international law as "crimes" and to abandon the practice of Falun Gong. He was not

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formally charged until almost a month later.

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DATED: September 2, 2011

Respectfully submitted,

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SCHWARCZ, RIMBERG, BOYD &
RADER, LLP

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By:

/s/ K. Lee Crawford-Boyd
K. Lee Crawford-Boyd, Esq.
Attorney for Plaintiffs
Terri E. Marsh, Esq.
HUMAN RIGHTS LEGAL FOUNDATION
Attorney for Plaintiffs

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Judith Brown Chomsky, Esq.
LAW OFFICES OF JUDITH BROWN
CHOMSKY
To be admitted pro hac vice
Attorney for Plaintiffs

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SCHWARCZ, RIMBERG,
BOYD & RADER, LLP
6310 San Vicente Blvd
Los Angeles, CA 90048

NOTICE OF ERRATA RE: FIRST AMENDED COMPLAINT
Case No. 5:11-cv-02449-JF-PSGx