Doe I et al v. Cisco Systems, Inc. et al
Filing
73
STIPULATION and [Proposed] Order RE: BRIEFING SCHEDULE FOR 67 MOTION TO DISMISS 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 Declaration of Kristen Nelson ISO (Boyd, Kathryn) (Filed on 10/10/2011) Modified on 10/13/2011,(link to motion.) (cv, COURT STAFF).
1
2
3
4
5
6
7
8
9
10
11
12
13
KATHRYN LEE CRAWFORD-BOYD, ESQ. (SBN 189496)
lboyd@srbr-law.com
RAJIKA L. SHAH, ESQ. (SBN 232994)
rshah@srbr-law.com
SCHWARCZ, RIMBERG, BOYD & RADER, LLP
6310 San Vicente Boulevard, Suite 360
Los Angeles, California 90048
Phone: (323) 302-9488, Fax: (323) 931-4990
TERRI MARSH, ESQ. (pro hac vice)
terri.marsh@hrlf.net
BRIAN PIERCE, ESQ. (pro hac vice)
brianp@hrlf.net
HUMAN RIGHTS LAW FOUNDATION
1615 L Street NW, Suite 1100
Washington, D.C. 20036
Phone: (202) 369-4977, Fax: (323) 931-4990
JUDITH BROWN CHOMSKY (pro hac vice)
jchomsky@igc.org
LAW OFFICES OF JUDITH BROWN CHOMSKY
8210 New Second Street
Elkins Park, PA 19027
Phone: (215) 782-8327, Fax: (215)782-8368
Attorneys for PLAINTIFFS
14
15
UNITED STATES DISTRICT COURT FOR THE
16
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
Case No. 5:11-cv-02449-EJD
DOE I, DOE II, Ivy HE, DOE III, DOE IV,
DOE V, DOE VI, ROE VII, Charles LEE,
Assigned to the Honorable Edward J. Davila
ROE VIII, and LIU Guifu,
STIPULATION AND [PROPOSED]
Plaintiffs,
ORDER RE: BRIEFING SCHEDULE FOR
vs.
MOTION TO DISMISS
CISCO SYSTEMS, INC., John CHAMBERS,
Thomas LAM, Owen CHAN, Fredy
Action Filed: May 19, 2011
FAC Filed: September 2, 2011
CHEUNG, and DOES 1-100,
17
18
19
20
21
22
23
24
Defendants.
Hearing: February 17, 2012
Time: 9:00 am
Courtroom: 1, 5th floor
25
26
27
28
STIPULATION AND [PROPOSED] ORDER RE:
BRIEFING SCHEDULE FOR MOTION TO DISMISS
Case No. 5:11-cv-02449-EJD
STIPULATION
1
2
IT IS HEREBY STIPULATED AND AGREED between DOE I, DOE II, Ivy HE, DOE
3
III, DOE IV, DOE V, DOE VI, ROE VII, Charles LEE, ROE VIII, and LIU Guifu (“Plaintiffs”)
4
and Defendants CISCO SYSTEMS, INC. (“Cisco”), John CHAMBERS (“Chambers”), Thomas
5
LAM (“Lam”), Owen CHAN (“Chan”), and Fredy CHEUNG (“Cheung”) (“Defendants”)
6
(collectively, the “Parties”), as follows:
WHEREAS, pursuant to Fed. R. Civ. P. 15(a)(1)(B) and by stipulation, Plaintiffs filed a
7
8
Corrected First Amended Complaint (“FAC”) on September 2, 2011 (Docket Entry (“DE”) 62-1);
WHEREAS, on September 23, 2011, Defendants filed a Motion to Dismiss the FAC
9
10
(“Motion to Dismiss”) (DE 67);
WHEREAS, pursuant to discussions between counsel, the Parties agreed to extend the
11
12
briefing schedule on the Motion to Dismiss;
WHEREAS, in mid-August 2011, Terri Marsh, lead trial counsel for Plaintiffs, was
13
14
involved in a head-on automobile collision and suffered injuries including whiplash, facial
15
contusions, and minor cuts and bruises, took a one-month leave of absence from work, and has
16
been ordered by her doctor to work only part-time through the remainder of the year for medical
17
reasons, and Plaintiffs accordingly requested that their Opposition be due on November 18, 2011;
WHEREAS, counsel for Defendants have scheduling conflicts between mid-November
18
19
and mid-December 2011, and Defendants accordingly requested that their Reply be due on
20
January 16, 2012;
21
WHEREAS, the Motion to Dismiss will be fully briefed by mid-January 2012;
22
NOW THEREFOR IT IS HEREBY STIPULATED, by and between the Parties,
23
through their respective counsel, subject to and in accordance with the recitations set forth above,
24
that:
25
26
1.
Plaintiffs’ Opposition to the Motion to Dismiss and any and all supporting
documents are due no later than November 18, 2011;
Defendants’ Reply and any and all supporting documents are due no later than
27
2.
28
January 16, 2012;
-1STIPULATION AND [PROPOSED] ORDER RE:
BRIEFING SCHEDULE FOR MOTION TO DISMISS
Case No. 5:11-cv-02449-EJD
3.
1
The Motion to Dismiss is scheduled to be heard at 9:00am on February 17, 2010,
2
in Courtroom 1, 5th Floor, of the above-referenced Court.1
3
DATED: October 10, 2011
4
5
SCHWARCZ, RIMBERG, BOYD &
RADER, LLP
By:
6
7
DATED: October 10, 2011
/s/ K. Lee Boyd
K. Lee Boyd, Esq.
HUMAN RIGHTS LAW FOUNDATION
8
By:
9
10
DATED: October 10, 2011
/s/ Terri E. Marsh
Terri E. Marsh, Esq. (pro hac vice)
LAW OFFICES OF JUDITH BROWN CHOMSKY
11
12
By:
13
Attorneys for Plaintiffs
14
15
/s/ Judith B. Chomsky
Judith B. Chomsky, Esq. (pro hac vice)
DATED: October 10, 2011
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
16
17
By:
18
19
/s/ Kathleen Sullivan
Kathleen Sullivan, Esq.2
Isaac Nesser, Esq.
Attorneys for Defendants
20
21
22
PURSUANT TO STIPULATION, IT IS SO ORDERED.
23
24
DATED:_________________, 2011
25
________________________________
Hon. Edward J. Davila
United States District Judge
26
27
28
1
Pursuant to the Hon. Edward J. Davila’s Scheduling Notes, on October 6, 2011, counsel for
Plaintiffs tentatively reserved a hearing date of February 17, 2011, for the Motion to Dismiss.
2
I have given my consent for Plaintiffs to electronically sign this Stipulation on my behalf.
-2STIPULATION AND [PROPOSED] ORDER RE:
BRIEFING SCHEDULE FOR MOTION TO DISMISS
Case No. 5:11-cv-02449-EJD
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?