Daobin et al v. CISCO Systems, Inc. et al

Filing 18

Joint MOTION for Extension of Time to Respond to the Complaint by CISCO Systems, Inc. Responses due by 8/8/2011 (Attachments: # 1 Text of Proposed Order)(Bisbee, Lincoln)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
Du Daobin, et al.

Plaintiff,
v.
CISCO Systems, Inc., et al.

Defendant.

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Civil Action No. 8:11-cv-01538 PJM

JOINT MOTION FOR EXTENSION OF TIME
TO RESPOND TO THE COMPLAINT1
The parties to the above-captioned matter, by and through their undersigned counsel,
submit the following Joint Motion For Extension Of Time To Respond To The Complaint.
WHEREAS, Plaintiffs’ Complaint implicates complex issues of international law and
domestic law, including under the Alien Tort Statute and Torture Victim Protection Act; and
WHEREAS, Defendants intend to seek a stay of their response to the Complaint, and of
further progress in this action, pending (a) the disposition of Defendants’ motion to dismiss the
complaint in Doe v. Cisco, No. 5:11-cv-02449 (N.D. Cal.) and (b) a decision by the Fourth
Circuit Court of Appeals in Aziz v. Alcolac, No. 10-1908; and
WHEREAS, Plaintiffs oppose Defendants’ requested stay; and
WHEREAS, the Parties have agreed to adjourn Defendants’ response to the Complaint
pending this Court’s resolution of Defendants’ request for a stay;
NOW, THEREFORE, the Parties stipulate and jointly move the Court to enter an
Order stating as follows:
1.
If this Court denies Defendants’ request for a stay, then the Defendants shall
respond to the Complaint within 30 days of such Order.
2.
If this Court grants Defendants’ request for a stay in any respect, then the
Defendants shall respond to the Complaint within 30 days of the expiration of such a stay.
1

By consent motion of the parties, the deadline for all Defendants to answer or otherwise respond to the Complaint
was previously extended to July 25, 2011.

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22566081.1

3.
Plaintiffs’ brief in opposition to any motion to dismiss shall be due 30 days
following the service of such motion by Defendants.
4.
Defendants’ reply brief in further support of any motion to dismiss shall be due 21
days following the service of such Opposition Brief by Plaintiffs.
Dated: July 21, 2011
Respectfully submitted,

/S/
Lincoln O. Bisbee
MORGAN, LEWIS & BOCKIUS LLP
1111 Pennsylvania Avenue NW
Washington, DC 20004
[e-mail]
T: [phone]
F: [phone]

______/S/___________________
Daniel S. Ward
WARD & WARD, P.L.L.C.
2020 N. St., NW
Washington, DC 20036
[e-mail]
T: [phone]
Counsel for Plaintiff

Counsel for Defendants

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22566081.1

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that true and correct copies of the foregoing was served
electronically via ECF to the following:

Daniel S. Ward
WARD & WARD, P.L.L.C.
2020 N. St., NW
Washington, DC 20036
Counsel for Plaintiff

___/s/_____
Lincoln O. Bisbee
Counsel for Defendant

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22566081.1