CISCO SYSTEMS CLASS ACTION LITIGATION

INSTITUTIONAL SHAREHOLDERS GROUP
CISCO INVESTORS GROUP
COUNSEL
BRODY
LEAD PLTF MOTIONS
SUNITA REDDY
BISHOP
RADIANT ADVISORS
LLC
LEAD PLAINTIFF
SUPPORT
PATRICE
THEREOF
OPP
COURT
FERMAGLICH
PROPOSED LEAD
LITIGATION
MPA
APPOINTED LEAD PLAINTIFF
COURT APPROVE
TOTAL RECOVERY
PENSION FUND
PSLRA
LOS ANGELES
WILSHIRE BLVD
REPRESENTING
ATTORNEYS
SECURITIES

 1 STULL, STULL & BRODY
      Michael D. Braun (167416)
 2 Patrice L. Bishop (182256)
      10940 Wilshire Blvd. Suite 2300
 3 Los Angeles, CA 90024
      (310) 209-2468
 4 (310) 209-2087 - fax

 5 Counsel for Movant, Proposed Lead Class Counsel

 6 WEISS & YOURMAN
      Jordan L. Lurie (130013)
 7 Mark A. Gordon (160113)
      10940 Wilshire Blvd., 24th Floor
 8 Los Angeles, CA 90024
      (310) 208-2800
 9 (310) 209-2348 - fax

10 STULL, STULL & BRODY
      Jules Brody
11 Howard T. Longman
      6 East 45th Street
12 New York, NY 10017
      (212) 687-7320
13 (212) 490-2022 - fax

14 Attorneys for Plaintiffs

15                                          UNITED STATES DISTRICT COURT

16                                      NORTHERN DISTRICT OF CALIFORNIA

17                                                      SAN JOSE DIVISION

18

19 PLUMBERS & PIPEFITTERS LOCAL 572                                     ) CASE NO.: CV 01-20418 JW
      PENSION FUND, On Behalf of Itself and All                         )
20 Others Similarly Situated,                                           ) CLASS ACTION
                                                                        )
21                                 Plaintiff,                           ) WARREN FERMAGLICH'S
                                                                        ) OPPOSITION TO THE LEAD
22                       v.                                             ) MOTIONS OF THE CISCO
                                                                        ) GROUP, THE CISCO
23 CISCO SYSTEMS, INC., JOHN T.                                         ) SHAREHOLDERS GROUP,
      CHAMBERS, LARRY R. CARTER, GARY J. ) ADVISORS, LLC, AND SUNITA REDDY;
24 DAICHENDT, JUDITH L. ESTRIN, CHARLES ) MEMORANDUM OF POINTS AND
      H. GIANCARLO, MARIO MAZZOLA, CARL ) AUTHORITIES IN SUPPORT THEREOF;
25 REDFIELD, MICHELANGELO VOLPI,                                        ) DECLARATION OF PATRICE L.

SNIPPETS:

STULL, STULL & BRODY

Patrice L. Bishop

Los Angeles, CA 90024

Counsel for Movant, Proposed Lead Class Counsel

10940 Wilshire Blvd., 24th Floor

WARREN FERMAGLICH'S OPP.

TO THE LEAD PLTF MOTIONS OF THE CISCO INVESTORS GROUP, THE CISCO INSTITUTIONAL SHAREHOLDERS

OF PATRICE L. BISHOP

Investors Group,2 the Cisco Institutional Shareholders Group,3 Radiant Advisors, LLC,4 and

Reddy,5 and their requests for approval of their attorneys of record as lead counsel for this

Mr. Fermaglich requests the Court appoint him lead counsel on behalf of himself, his wife,

Class, and requests the Court approve Stull, Stull & Brody as lead counsel.

12 the dictates of the PSLRA, Mr. Fermaglich should be appointed lead plaintiff.

21 Southeast and Southwest Areas Pension Fund, the Plumbers & Pipefitters National Pension

appointment would ensure the smooth governance of the action and compliance with the PSLRA.

12 largest personal interest in this litigation, the Court should appoint Mr. Fermaglich as

26 Pursuant to Section 21d of the Securities Exchange Act of 1934; to Approve Lead

19 class that the court determines to be the most capable of adequately representing the

17 request the Court approve a fee that is no more than 15% of the Class's total recovery.

2 . COMPLAINT B 9

EXTRACTED KEY WORDS

CHAMBERS
CISCO SYSTEMS
DEFENDANT
SALES
CLASS PERIOD
JOHN
REVENUE
CISCO STOCK
DEMAND
CARTER
ACQUISITIONS
GROWTH
CUSTOMERS
MARKET
INVENTORY
ARTIFICIALLY INFLATED PRICES
NET INCOME
SECURITIES
SERVICE PROVIDERS
EPS
CONFIDENTIAL CISCO INFORMATION
CALIFORNIA
UNITED STATES
INVENTORIES
VENDOR FINANCING
TECHNOLOGY
CARL REDFIELD
SENIOR VICE PRESIDENT-FINANCE
SUBSTANTIAL TECHNICAL DEFECTS



   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   DARREN J. ROBBINS (168593)
   SPENCER A. BURKHOLZ (147029)
   DANIEL S. DROSMAN (200643)
   FREDERICK B. BURNSIDE (211089)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
   619/231-7423 (fax)

   SPECTER SPECTER EVANS
   & MANOGUE, P.C.
   JOHN C. EVANS
   Koppers Building, 26th Floor
   436 7th Avenue
   Pittsburgh, PA 15219-1818
   Telephone: 412/642-2300
   412/642-2309 (fax)

   Attorneys for Plaintiff

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA



   MICHAEL F. CAMPANELLA, On Behalf
   of Himself and All Others Similarly Situated,

                           Plaintiff,

       vs.

   CISCO SYSTEMS, INC., JOHN T.
   CHAMBERS, LARRY R. CARTER, GARY J.
   DAICHENDT, JUDITH L. ESTRIN,
   CHARLES H. GIANCARLO, MARIO
   MAZZOLA, CARL REDFIELD,
   MICHELANGELO VOLPI, CAROL A.
   BARTZ, JAMES F. GIBBONS, STEVEN M.
   WEST, EDWARD R. KOZEL and
   ROBERT L. PUETTE,

SNIPPETS:

P.C. JOHN C. EVANS

COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS

DEMAND FOR JURY TRIAL

This is a securities fraud class action on behalf of persons who purchased Cisco Systems,

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive

Through this manipulation and the shipment of defective or incomplete products, as well as

The inflation in Cisco's stock price was essential to its main corporate strategy - that of

In addition, each of the defendants had the motive and the opportunity to perpetrate the

Defendants' misconduct has wiped out over $400 billion in market capitalization as Cisco

Defendant Cisco maintains its headquarters at San Jose, California.

Defendant John T. Chambers was, during the Class Period, President, Chief Executive Officer,

During the Class Period, while in possession of confidential Cisco information, Chambers sold

Defendant Larry R. Carter was, during the Class Period, Senior Vice President-Finance and

During the Class Period, while in possession of confidential Cisco information, Carter sold

Defendant Carl Redfield was, during the Class Period, Senior Vice President-Manufacturing and

Carter was at all relevant times Senior Vice President-Finance and Administration, Chief

management of the Company knew that much of Cisco's sales growth was being generated by

The financial reporting system is so efficient that Cisco, in essence, is able to close its

Cisco's top executives received daily reports on product sales and product inventories that

In addition to depriving Cisco of revenue needed to meet its revenue and EPS forecasts and

Cisco was artificially inflating its reported revenues, net income and EPS through a variety

Cisco was recording revenue on the sale of products to indirect customers where it had loaned

Cisco's summa switch had substantial technical defects and quality problems which were

Many of Cisco's acquisitions were extremely disappointing, as products acquired were not yet

Cisco's stock plunged on these revelations - falling from $36-3/16 to $29-7/8, a 17% drop on

3 . COMPLAINT B 8

EXTRACTED KEY WORDS

CHAMBERS
CISCO SYSTEMS
DEFENDANT
SALES
CLASS PERIOD
REVENUE
JOHN
CISCO STOCK
DEMAND
CARTER
ACQUISITIONS
GROWTH
CUSTOMERS
MARKET
INVENTORY
ARTIFICIALLY INFLATED PRICES
NET INCOME
SECURITIES
SERVICE PROVIDERS
EPS
CONFIDENTIAL CISCO INFORMATION
CALIFORNIA
UNITED STATES
INVENTORIES
VENDOR FINANCING
TECHNOLOGY
CARL REDFIELD
SENIOR VICE PRESIDENT-FINANCE
SUBSTANTIAL TECHNICAL DEFECTS



   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   DARREN J. ROBBINS (168593)
   SPENCER A. BURKHOLZ (147029)
   DANIEL S. DROSMAN (200643)
   FREDERICK B. BURNSIDE (211089)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
   619/231-7423 (fax)

   SAVETT FRUTKIN PODELL &
   RYAN, P.C.
   STUART H. SAVETT
   325 Chestnut Street, Suite 700
   Philadelphia, PA 19106
   Telephone: 215/923-5400
   215/923-9353 (fax)

   LAW OFFICES OF RICHARD
   APPLEBY
   RICHARD APPLEBY
   42 Broadway, 19th Floor
   New York, NY 10004
   Telephone: 212/344-1800
   212/809-6174 (fax)

   Attorneys for Plaintiff


                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA



   STANLEY MAURER, On Behalf of
   Himself and All Others Similarly Situated,

                           Plaintiff,

       vs.

   CISCO SYSTEMS, INC., JOHN T.
   CHAMBERS, LARRY R. CARTER, GARY J.

SNIPPETS:

COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS

DEMAND FOR JURY TRIAL

This is a securities fraud class action on behalf of persons who purchased Cisco Systems,

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive

Through this manipulation and the shipment of defective or incomplete products, as well as

The inflation in Cisco's stock price was essential to its main corporate strategy - that of

In addition, each of the defendants had the motive and the opportunity to perpetrate the

Defendants' misconduct has wiped out over $400 billion in market capitalization as Cisco

Defendant Cisco maintains its headquarters at San Jose, California.

Defendant John T. Chambers was, during the Class Period, President, Chief Executive Officer,

During the Class Period, while in possession of confidential Cisco information, Chambers sold

Defendant Larry R. Carter was, during the Class Period, Senior Vice President-Finance and

During the Class Period, while in possession of confidential Cisco information, Carter sold

Defendant Carl Redfield was, during the Class Period, Senior Vice President-Manufacturing and

Carter was at all relevant times Senior Vice President-Finance and Administration, Chief

management of the Company knew that much of Cisco's sales growth was being generated by

The financial reporting system is so efficient that Cisco, in essence, is able to close its

Cisco's top executives received daily reports on product sales and product inventories that

In addition to depriving Cisco of revenue needed to meet its revenue and EPS forecasts and

Cisco was artificially inflating its reported revenues, net income and EPS through a variety

Cisco was recording revenue on the sale of products to indirect customers where it had loaned

Cisco's summa switch had substantial technical defects and quality problems which were

Many of Cisco's acquisitions were extremely disappointing, as products acquired were not yet

Cisco's stock plunged on these revelations - falling from $36-3/16 to $29-7/8, a 17% drop on

4 . COMPLAINT B 7

EXTRACTED KEY WORDS

CHAMBERS
CISCO SYSTEMS
DEFENDANT
SALES
CLASS PERIOD
REVENUE
CISCO STOCK
JOHN
DEMAND
CARTER
ACQUISITIONS
GROWTH
CUSTOMERS
MARKET
INVENTORY
ARTIFICIALLY INFLATED PRICES
NET INCOME
SECURITIES
SERVICE PROVIDERS
EPS
CONFIDENTIAL CISCO INFORMATION
CALIFORNIA
UNITED STATES
INVENTORIES
VENDOR FINANCING
TECHNOLOGY
CARL REDFIELD
SENIOR VICE PRESIDENT-FINANCE
SUBSTANTIAL TECHNICAL DEFECTS



   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   DARREN J. ROBBINS (168593)
   SPENCER A. BURKHOLZ (147029)
   FREDERICK B. BURNSIDE (211089)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
   619/231-7423 (fax)

   LAW OFFICES OF MARC S. HENZEL
   MARC S. HENZEL
   210 West Washington Square
   Third Floor
   Philadelphia, PA 19106-3503
   Telephone: 215/625-9999
   215/440-9475 (fax)

   LAW OFFICES OF BERNARD M.
   GROSS, P.C.
   DEBORAH R. GROSS
   1500 Walnut Street, Sixth Floor
   Philadelphia, PA 19102
   Telephone: 215/561-3600
   215/561-3000 (fax)

   Attorneys for Plaintiffs

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA



   IRIS HSU and BURT ROSEN, On Behalf
   of Themselves and All Others Similarly
   Situated,

                           Plaintiffs,

       vs.

   CISCO SYSTEMS, INC., JOHN T.
   CHAMBERS, LARRY R. CARTER, GARY
   J. DAICHENDT, JUDITH L. ESTRIN,

SNIPPETS:

COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS

DEMAND FOR JURY TRIAL

This is a securities fraud class action on behalf of persons who purchased Cisco Systems,

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive

Through this manipulation and the shipment of defective or incomplete products, as well as

The inflation in Cisco's stock price was essential to its main corporate strategy - that of

In addition, each of the defendants had the motive and the opportunity to perpetrate the

Defendants' misconduct has wiped out over $400 billion in market capitalization as Cisco

Defendant Cisco maintains its headquarters at San Jose, California.

Defendant John T. Chambers was, during the Class Period, President, Chief Executive Officer,

During the Class Period, while in possession of confidential Cisco information, Chambers sold

Defendant Larry R. Carter was, during the Class Period, Senior Vice President-Finance and

During the Class Period, while in possession of confidential Cisco information, Carter sold

Defendant Carl Redfield was, during the Class Period, Senior Vice President-Manufacturing and

Carter was at all relevant times Senior Vice President-Finance and Administration, Chief

management of the Company knew that much of Cisco's sales growth was being generated by

The financial reporting system is so efficient that Cisco, in essence, is able to close its

Cisco's top executives received daily reports on product sales and product inventories that

In addition to depriving Cisco of revenue needed to meet its revenue and EPS forecasts and

Cisco was artificially inflating its reported revenues, net income and EPS through a variety

Cisco was recording revenue on the sale of products to indirect customers where it had loaned

Cisco's summa switch had substantial technical defects and quality problems which were

Many of Cisco's acquisitions were extremely disappointing, as products acquired were not yet

Cisco's stock plunged on these revelations - falling from $36-3/16 to $29-7/8, a 17% drop on

5 . COMPLAINT B 6

EXTRACTED KEY WORDS

CHAMBERS
CISCO SYSTEMS
DEFENDANT
SALES
CLASS PERIOD
REVENUE
JOHN
CISCO STOCK
DEMAND
CARTER
ACQUISITIONS
GROWTH
CUSTOMERS
MARKET
INVENTORY
ARTIFICIALLY INFLATED PRICES
NET INCOME
SECURITIES
SERVICE PROVIDERS
EPS
CONFIDENTIAL CISCO INFORMATION
CALIFORNIA
UNITED STATES
INVENTORIES
VENDOR FINANCING
TECHNOLOGY
CARL REDFIELD
SENIOR VICE PRESIDENT-FINANCE
SUBSTANTIAL TECHNICAL DEFECTS



   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   DARREN J. ROBBINS (168593)
   SPENCER A. BURKHOLZ (147029)
   FREDERICK B. BURNSIDE (211089)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
   619/231-7423 (fax)
       - and -
   REED R. KATHREIN (139304)
   100 Pine Street, Suite 2600
   San Francisco, CA 94111
   Telephone: 415/288-4545
   415/288-4534 (fax)

   LAW OFFICES OF BRIAN M. FELGOISE
   BRIAN M. FELGOISE
   230 South Broad Street, Suite 404
   Philadelphia, PA 19102
   Telephone: 215/735-6810
   215/735-5185 (fax)

   Attorneys for Plaintiff

   (Additional counsel appear on signature page.)


                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA




   VALERIE KOFSKY, On Behalf of Herself
   and All Others Similarly Situated,

                           Plaintiff,

       vs.

   CISCO SYSTEMS, INC., JOHN T.
   CHAMBERS, LARRY R. CARTER, GARY
   J. DAICHENDT, JUDITH L. ESTRIN,

SNIPPETS:

COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS

DEMAND FOR JURY TRIAL

This is a securities fraud class action on behalf of persons who purchased Cisco Systems,

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive

Through this manipulation and the shipment of defective or incomplete products, as well as

The inflation in Cisco's stock price was essential to its main corporate strategy - that of

In addition, each of the defendants had the motive and the opportunity to perpetrate the

Defendants' misconduct has wiped out over $400 billion in market capitalization as Cisco

Defendant Cisco maintains its headquarters at San Jose, California.

Defendant John T. Chambers was, during the Class Period, President, Chief Executive Officer,

During the Class Period, while in possession of confidential Cisco information, Chambers sold

Defendant Larry R. Carter was, during the Class Period, Senior Vice President-Finance and

During the Class Period, while in possession of confidential Cisco information, Carter sold

Defendant Carl Redfield was, during the Class Period, Senior Vice President-Manufacturing and

Carter was at all relevant times Senior Vice President-Finance and Administration, Chief

management of the Company knew that much of Cisco's sales growth was being generated by

The financial reporting system is so efficient that Cisco, in essence, is able to close its

Cisco's top executives received daily reports on product sales and product inventories that

In addition to depriving Cisco of revenue needed to meet its revenue and EPS forecasts and

Cisco was artificially inflating its reported revenues, net income and EPS through a variety

Cisco was recording revenue on the sale of products to indirect customers where it had loaned

Cisco's summa switch had substantial technical defects and quality problems which were

Many of Cisco's acquisitions were extremely disappointing, as products acquired were not yet

Cisco's stock plunged on these revelations - falling from $36-3/16 to $29-7/8, a 17% drop on

6 . COMPLAINT B 5

EXTRACTED KEY WORDS

CHAMBERS
CISCO SYSTEMS
DEFENDANT
SALES
CLASS PERIOD
REVENUE
CISCO STOCK
JOHN
CARTER
ACQUISITIONS
GROWTH
CUSTOMERS
MARKET
INVENTORY
VIOLATION
ARTIFICIALLY INFLATED PRICES
NET INCOME
SERVICE PROVIDERS
EPS
CONFIDENTIAL CISCO INFORMATION
CALIFORNIA
UNITED STATES
INVENTORIES
VENDOR FINANCING
TECHNOLOGY
CARL REDFIELD
SENIOR VICE PRESIDENT-FINANCE
SUBSTANTIAL TECHNICAL DEFECTS
POSSESSION



   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   DARREN J. ROBBINS (168593)
   SPENCER A. BURKHOLZ (147029)
   FREDERICK B. BURNSIDE (211089)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
   619/231-7423 (fax)
       - and -
   REED R. KATHREIN (139304)
   100 Pine Street, Suite 2600
   San Francisco, CA 94111
   Telephone: 415/288-4545
   415/288-4534 (fax)

   FRUCHTER & TWERSKY
   JACK G. FRUCHTER
   60 East 42nd Street, 47th Floor
   New York, NY 10165
   Telephone: 212/687-6655
   212/557-6151 (fax)

   LAW OFFICES OF BRUCE G. MURPHY
   BRUCE G. MURPHY
   265 Llwyds Lane
   Vero Beach, FL 32963
   Telephone: 561/231-4202
   561/231-4042 (fax)

    Attorneys for Plaintiffs


                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA



   HARRIET SCHNEIER, IRA and ANDREW
   MURRAY, On Behalf of Themselves and
   All Others Similarly Situated,

                           Plaintiffs,

SNIPPETS:

This is a securities fraud class action on behalf of persons who purchased Cisco Systems,

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive

Through this manipulation and the shipment of defective or incomplete products, as well as

The inflation in Cisco's stock price was essential to its main corporate strategy - that of

In addition, each of the defendants had the motive and the opportunity to perpetrate the

Defendants' misconduct has wiped out over $400 billion in market capitalization as Cisco

Defendant Cisco maintains its headquarters at San Jose, California.

Defendant John T. Chambers was, during the Class Period, President, Chief Executive Officer,

During the Class Period, while in possession of confidential Cisco information, Chambers sold

Defendant Larry R. Carter was, during the Class Period, Senior Vice President-Finance and

During the Class Period, while in possession of confidential Cisco information, Carter sold

Defendant Carl Redfield was, during the Class Period, Senior Vice President-Manufacturing and

Carter was at all relevant times Senior Vice President-Finance and Administration, Chief

management of the Company knew that much of Cisco's sales growth was being generated by

The financial reporting system is so efficient that Cisco, in essence, is able to close its

Cisco's top executives received daily reports on product sales and product inventories that

In addition to depriving Cisco of revenue needed to meet its revenue and EPS forecasts and

Cisco was artificially inflating its reported revenues, net income and EPS through a variety

Cisco was recording revenue on the sale of products to indirect customers where it had loaned

Cisco's summa switch had substantial technical defects and quality problems which were

Many of Cisco's acquisitions were extremely disappointing, as products acquired were not yet

Cisco had accumulated hundreds of millions of dollars worth of overvalued and excess

Cisco's stock plunged on these revelations - falling from $36-3/16 to $29-7/8, a 17% drop on

7 . COMPLAINT B 4

EXTRACTED KEY WORDS

CHAMBERS
CISCO SYSTEMS
DEFENDANT
SALES
CLASS PERIOD
REVENUE
JOHN
CISCO STOCK
DEMAND
CARTER
ACQUISITIONS
GROWTH
CUSTOMERS
MARKET
INVENTORY
ARTIFICIALLY INFLATED PRICES
NET INCOME
SECURITIES
SERVICE PROVIDERS
EPS
CONFIDENTIAL CISCO INFORMATION
CALIFORNIA
UNITED STATES
INVENTORIES
VENDOR FINANCING
TECHNOLOGY
CARL REDFIELD
SENIOR VICE PRESIDENT-FINANCE
SUBSTANTIAL TECHNICAL DEFECTS



   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   DARREN J. ROBBINS (168593)
   SPENCER A. BURKHOLZ (147029)
   FREDERICK B. BURNSIDE (211089)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
   619/231-7423 (fax)
       - and -
   MICHAEL R.R. REESE (206773)
   100 Pine Street, Suite 2600
   San Francisco, CA 94111
   Telephone: 415/288-4545
   415/288-4534 (fax)

   SCOTT & SCOTT, LLC
   DAVID R. SCOTT
   JAMES E. MILLER
   108 Norwich Avenue
   Colchester, CT 06415
   Telephone: 860/537-3818
   860/537-4432 (fax)

   Attorneys for Plaintiff


                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA



   JOSEPH CARESIO, On Behalf of Himself
   and All Others Similarly Situated,

                           Plaintiff,

       vs.

   CISCO SYSTEMS, INC., JOHN T.
   CHAMBERS, LARRY R. CARTER, GARY
   J. DAICHENDT, JUDITH L. ESTRIN,
   CHARLES H. GIANCARLO, MARIO
   MAZZOLA, CARL REDFIELD,

SNIPPETS:

COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS

DEMAND FOR JURY TRIAL

This is a securities fraud class action on behalf of persons who purchased Cisco Systems,

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive

Through this manipulation and the shipment of defective or incomplete products, as well as

The inflation in Cisco's stock price was essential to its main corporate strategy - that of

In addition, each of the defendants had the motive and the opportunity to perpetrate the

Defendants' misconduct has wiped out over $400 billion in market capitalization as Cisco

Defendant Cisco maintains its headquarters at San Jose, California.

Defendant John T. Chambers was, during the Class Period, President, Chief Executive Officer,

During the Class Period, while in possession of confidential Cisco information, Chambers sold

Defendant Larry R. Carter was, during the Class Period, Senior Vice President-Finance and

During the Class Period, while in possession of confidential Cisco information, Carter sold

Defendant Carl Redfield was, during the Class Period, Senior Vice President-Manufacturing and

Carter was at all relevant times Senior Vice President-Finance and Administration, Chief

management of the Company knew that much of Cisco's sales growth was being generated by

The financial reporting system is so efficient that Cisco, in essence, is able to close its

Cisco's top executives received daily reports on product sales and product inventories that

In addition to depriving Cisco of revenue needed to meet its revenue and EPS forecasts and

Cisco was artificially inflating its reported revenues, net income and EPS through a variety

Cisco was recording revenue on the sale of products to indirect customers where it had loaned

Cisco's summa switch had substantial technical defects and quality problems which were

Many of Cisco's acquisitions were extremely disappointing, as products acquired were not yet

Cisco's stock plunged on these revelations - falling from $36-3/16 to $29-7/8, a 17% drop on

8 . COMPLAINT B 3

EXTRACTED KEY WORDS

CHAMBERS
CISCO SYSTEMS
SALES
CLASS PERIOD
REVENUE
JOHN
CISCO STOCK
CARTER
ACQUISITIONS
CUSTOMERS
GROWTH
ANALYSTS
MARKET
SHARES
INVENTORY
ARTIFICIALLY INFLATED PRICES
EXECUTIVES
NET INCOME
EPS
SERVICE PROVIDERS
CALIFORNIA
PLAINTIFFS
CONFIDENTIAL CISCO INFORMATION
INVENTORIES
TECHNOLOGY
CARL REDFIELD
UNITED STATES
SENIOR VICE PRESIDENT-FINANCE
SUCCESSFUL



   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   DARREN J. ROBBINS (168593)
   SPENCER A. BURKHOLZ (147029)
   FREDERICK B. BURNSIDE (211089)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
   619/231-7423 (fax)
       - and -
   MICHAEL R.R. REESE (206773)
   100 Pine Street, Suite 2600
   San Francisco, CA 94111
   Telephone: 415/288-4545
   415/288-4534 (fax)

   SCHIFFRIN & BARROWAY, LLP
   MARC A. TOPAZ
   Three Bala Plaza East, Suite 400
   Bala Cynwyd, PA 19004
   Telephone: 610/667-7706
   610/667-7056 (fax)

   WECHSLER HARWOOD HALEBIAN
   & FEFFER LLP
   JOHN HALEBIAN
   488 Madison Avenue, 8th Floor
   New York, NY 10022
   Telephone: 212/935-7400
   212/753-3630 (fax)

   BERNSTEIN LIEBHARD & LIFSHITZ, LLP
   MICHAEL S. EGAN
   10 East 40th Street
   New York, NY 10016
   Telephone: 212/779-1414
   212/779-3218 (fax)

    Attorneys for Plaintiffs


                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA

SNIPPETS:

WECHSLER HARWOOD HALEBIAN & FEFFER LLP JOHN HALEBIAN

Attorneys for Plaintiffs

This is a securities fraud class action on behalf of persons who purchased Cisco Systems,

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive

Through this manipulation and the shipment of defective or incomplete products, as well as

The inflation in Cisco's stock price was essential to its main corporate strategy - that of

In addition, each of the defendants had the motive and the opportunity to perpetrate the

Defendants' misconduct has wiped out over $400 billion in market capitalization as Cisco

Defendant Cisco maintains its headquarters at San Jose, California.

Defendant John T. Chambers was, during the Class Period, President, Chief Executive Officer,

During the Class Period, while in possession of confidential Cisco information, Chambers sold

Defendant Larry R. Carter was, during the Class Period, Senior Vice President-Finance and

During the Class Period, while in possession of confidential Cisco information, Carter sold

Defendant Carl Redfield was, during the Class Period, Senior Vice President-Manufacturing and

Cisco's Senior Executives

Carter was at all relevant times Senior Vice President-Finance and Administration, Chief

The financial reporting system is so efficient that Cisco, in essence, is able to close its

Cisco's top executives received daily reports on product sales and product inventories that

Earlier in F00, in an effort to assure itself of a sufficient quantity of component parts to

In addition to depriving Cisco of revenue needed to meet its revenue and EPS forecasts and

Cisco was artificially inflating its reported revenues, net income and EPS through a variety

Cisco was recording revenue on the sale of products to indirect customers where it had loaned

Many of Cisco's acquisitions were extremely disappointing, as products acquired were not yet

This was often commented upon by defendants and analysts following Cisco.

Cisco's stock plunged on these revelations - falling from $36-3/16 to $29-7/8, a 17% drop on

9 . COMPLAINT B 2

EXTRACTED KEY WORDS

CHAMBERS
CISCO SYSTEMS
DEFENDANT
SALES
CLASS PERIOD
REVENUE
CISCO STOCK
JOHN
DEMAND
CARTER
ACQUISITIONS
VIOLATION
CUSTOMERS
GROWTH
ANALYSTS
ARTIFICIALLY INFLATED PRICES
EXECUTIVES
NET INCOME
SECURITIES
EPS
SERVICE PROVIDERS
CALIFORNIA
CONFIDENTIAL CISCO INFORMATION
INVENTORIES
TECHNOLOGY
CARL REDFIELD
UNITED STATES
SENIOR VICE PRESIDENT-FINANCE
SUCCESSFUL



   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   DARREN J. ROBBINS (168593)
   SPENCER A. BURKHOLZ (147029)
   FREDERICK B. BURNSIDE (211089)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
   619/231-7423 (fax)
       - and -
   MICHAEL R.R. REESE (206773)
   100 Pine Street, Suite 2600
   San Francisco, CA 94111
   Telephone: 415/288-4545
   415/288-4534 (fax)

   Attorneys for Plaintiff

   (Additional counsel appear on signature page.)


                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA



   PIRELLI ARMSTRONG TIRE
   CORPORATION RETIREE MEDICAL
   BENEFITS TRUST, On Behalf of Itself
   and All Others Similarly Situated,

                           Plaintiff,

       vs.

   CISCO SYSTEMS, INC., JOHN T.
   CHAMBERS, LARRY R. CARTER, GARY
   J. DAICHENDT, JUDITH L. ESPRIN,
   CHARLES H. GIANCARLO, MARIO
   MAZZOLA, CARL REDFIELD,
   MICHELANGELO VOLPI, CAROL A.
   BARTZ, JAMES F. GIBBONS, STEVEN M.
   WEST, EDWARD R. KOZEL and ROBERT
   L. PUETTE,

SNIPPETS:

COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS

DEMAND FOR JURY TRIAL

This is a securities fraud class action on behalf of persons who purchased Cisco Systems,

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive

The inflation in Cisco's stock price was essential to its main corporate strategy - that of

Defendants' misconduct has wiped out over $400 billion in market capitalization as Cisco

Defendant Cisco maintains its headquarters at San Jose, California.

Defendant John T. Chambers was, during the Class Period, President, Chief Executive Officer,

During the Class Period, while in possession of confidential Cisco information, Chambers sold

Defendant Larry R. Carter was, during the Class Period, Senior Vice President-Finance and

During the Class Period, while in possession of confidential Cisco information, Carter sold

Defendant Carl Redfield was, during the Class Period, Senior Vice President-Manufacturing and

Cisco's Senior Executives

Carter was at all relevant times Senior Vice President-Finance and Administration, Chief

The financial reporting system is so efficient that Cisco, in essence, is able to close its

Cisco's top executives received daily reports on product sales and product inventories that

Earlier in F00, in an effort to assure itself of a sufficient quantity of component parts to

In addition to depriving Cisco of revenue needed to meet its revenue and EPS forecasts and

Cisco was artificially inflating its reported revenues, net income and EPS through a variety

Cisco was recording revenue on the sale of products to indirect customers where it had loaned

Many of Cisco's acquisitions were extremely disappointing, as products acquired were not yet

Cisco had accumulated hundreds of millions of dollars worth of overvalued and excess

This was often commented upon by defendants and analysts following Cisco.

Cisco's stock plunged on these revelations - falling from $36-3/16 to $29-7/8, a 17% drop on

10 . COMPLAINT B 1

EXTRACTED KEY WORDS

STOCK
CHAMBERS
SALES
CUSTOMERS
ARTIFICIALLY INFLATED PRICES
REVENUE
SHARES
VIOLATION
INVENTORY
MARKET
CARTER
PURCHASE
GROWTH
CONFIDENTIAL CISCO INFORMATION
BUSINESS
ACQUISITION
EXECUTIVES
POSSESSION
SERVICE PROVIDERS
COMMON STOCK
STULL
INVENTORIES
INCOMPLETE PRODUCTS
DEFECTIVE SUMMA SWITCHES
SUBSTANTIAL REMEDIAL WORK
SUCCESSFUL
DISTRIBUTOR
EPS
FEDERAL SECURITIES LAWS

 1 WEISS & YOURMAN
      KEVIN J. YOURMAN (147159)
 2 MARK A. GORDON (160113)
      10940 Wilshire Blvd., 24th Floor
 3 Los Angeles, CA 90024
      (310) 208-2800
 4 (310) 209-2348 - fax
 5 STULL, STULL & BRODY
      MICHAEL D. BRAUN (167416)
 6 PATRICE L. BISHOP (182256)
      10940 Wilshire Blvd. Suite 2300
 7 Los Angeles, CA 90024
      (310) 209-2468
 8 (310) 209-2087 - fax
 9 STULL, STULL & BRODY
      JULES BRODY
10 6 East 45th Street
      New York, NY 10017
11 (212) 687-7320
      (212) 490-2022 - fax
12 Counsel for Plaintiffs
13
14
15                                 UNITED STATES DISTRICT COURT
16                              NORTHERN DISTRICT OF CALIFORNIA
17 ROSLIND J. WALANKA, as trustee for the ) No.:
18 Roslind J. Walanka Trust Account, On Behalf of )
      Herself and All Others Similarly Situated,    ) CLASS ACTION
19                                                  )
                                   Plaintiffs,      ) COMPLAINT FOR VIOLATIONS OF
20                                                  ) THE FEDERAL SECURITIES LAWS
             vs.                                    )
21                                                  )
      CISCO SYSTEMS, INC., JOHN T.                  )
22 CHAMBERS, LARRY R. CARTER, GARY J. )
      DAICHENDT, JUDITH L. ESTRIN,                  )
23 CHARLES H. GIANCARLO, MARIO                      )
      MAZZOLA, CARL REDFIELD,                       ) DEMAND FOR JURY TRIAL
24 MICHELANGELO VOLPI, CAROL A.                     )
      BARTZ, JAMES F. GIBBONS, STEVEN M.            )
25 WEST, EDWARD R. KOZEL and ROBERT L. )
      PUETTE,                                       )
26                                                  )
                                   Defendants.      )
27                                                  )
28


      COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS

SNIPPETS:

STULL, STULL & BRODY MICHAEL D. BRAUN

22 CHAMBERS, LARRY R. CARTER, GARY J.)

Inc. common stock between 8/10/99 and 4/16/01 (the "Class

against Cisco and its top officers and directors for violations of the federal securities laws

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive 10

12 financing conditional upon the purchase of large amounts of Cisco product.

13 manipulation and the shipment of defective or incomplete products, as well as Cisco's

16 positive but false statements about Cisco's products, financial results and business

19 of growth through acquisition, which Cisco accomplished through the exchange of inflated

22 own Cisco shares at prices as high as $80.24 per share, or 84% higher than the price to

EPS of only $0.18.

This disclosure shocked the market, causing Cisco's stock to decline to less than

that 3rdQ F01 sales would be less than $4.8 billion, or lower than any quarter since the 2ndQ

11 inventory of components in its service business.

During the Class Period, while in possession of confidential Cisco information, Carter

11 artificially inflated prices as high as $66-1/2 per share, for proceeds of more than

In fact Cisco's top executives receive monthly

15 Inventories of Finished Goods and Component Parts

17 in quantity if the new products were successful, Cisco had entered into unusual purchase

In addition to depriving Cisco of revenue needed to meet its revenue and EPS forecasts

18 to uncreditworthy customers who Cisco knew would likely be unable to repay their loans

ship what it knew were defective summa switches and record revenue on those shipments.

equipment, Cisco would require the buyer to purchase, through an intermediary such as a

14 knew would require either replacement of the product or substantial remedial work at great

Cisco's earnings were materially overstated in violation of GAAP as described in ¶¶76-93.

11 . COMPLAINT A

EXTRACTED KEY WORDS

CHAMBERS
CISCO SYSTEMS
DEFENDANT
SALES
CLASS PERIOD
REVENUE
CISCO STOCK
JOHN
DEMAND
CARTER
ACQUISITIONS
VIOLATION
CUSTOMERS
GROWTH
ANALYSTS
ARTIFICIALLY INFLATED PRICES
EXECUTIVES
NET INCOME
SECURITIES
EPS
SERVICE PROVIDERS
CALIFORNIA
CONFIDENTIAL CISCO INFORMATION
INVENTORIES
TECHNOLOGY
CARL REDFIELD
UNITED STATES
SENIOR VICE PRESIDENT-FINANCE
SUCCESSFUL



   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   DARREN J. ROBBINS (168593)
   SPENCER A. BURKHOLZ (147029)
   FREDERICK B. BURNSIDE (211089)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
   619/231-7423 (fax)
       - and -
   MICHAEL R.R. REESE (206773)
   100 Pine Street, Suite 2600
   San Francisco, CA 94111
   Telephone: 415/288-4545
   415/288-4534 (fax)
       - and -
   MELVYN I. WEISS
   One Pennsylvania Plaza
   New York, NY 10119-1065
   Telephone: 212/594-5300
   212/868-1229 (fax)

   Attorneys for Plaintiff

   (Additional counsel appear on signature page.)

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA


   PLUMBERS & PIPEFITTERS LOCAL
   572 PENSION FUND, On Behalf of
   Itself and All Others Similarly Situated,

                           Plaintiff,

       vs.

   CISCO SYSTEMS, INC., JOHN T.
   CHAMBERS, LARRY R. CARTER, GARY
   J. DAICHENDT, JUDITH L. ESTRIN,
   CHARLES H. GIANCARLO, MARIO
   MAZZOLA, CARL REDFIELD,
   MICHELANGELO VOLPI, CAROL A.

SNIPPETS:

COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS

DEMAND FOR JURY TRIAL

This is a securities fraud class action on behalf of persons who purchased Cisco Systems,

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive

The inflation in Cisco's stock price was essential to its main corporate strategy - that of

Defendants' misconduct has wiped out over $400 billion in market capitalization as Cisco

Defendant Cisco maintains its headquarters at San Jose, California.

Defendant John T. Chambers was, during the Class Period, President, Chief Executive Officer,

During the Class Period, while in possession of confidential Cisco information, Chambers sold

Defendant Larry R. Carter was, during the Class Period, Senior Vice President-Finance and

During the Class Period, while in possession of confidential Cisco information, Carter sold

Defendant Carl Redfield was, during the Class Period, Senior Vice President-Manufacturing and

Cisco's Senior Executives

Carter was at all relevant times Senior Vice President-Finance and Administration, Chief

The financial reporting system is so efficient that Cisco, in essence, is able to close its

Cisco's top executives received daily reports on product sales and product inventories that

Earlier in F00, in an effort to assure itself of a sufficient quantity of component parts to

In addition to depriving Cisco of revenue needed to meet its revenue and EPS forecasts and

Cisco was artificially inflating its reported revenues, net income and EPS through a variety

Cisco was recording revenue on the sale of products to indirect customers where it had loaned

Many of Cisco's acquisitions were extremely disappointing, as products acquired were not yet

Cisco had accumulated hundreds of millions of dollars worth of overvalued and excess

This was often commented upon by defendants and analysts following Cisco.

Cisco's stock plunged on these revelations - falling from $36-3/16 to $29-7/8, a 17% drop on

12 . NOTICE OF RESCHEDULING OF MOTION FOR APPOINTMENT

EXTRACTED KEY WORDS

APPOINTMENT
MOTION
RESCHEDULING
CISCO SYSTEMS
PLUMBERS
LOS ANGELES
SECURITIES
COUNSEL
STULL
CALIFORNIA
PURSUANT
APPROVE LEAD
EXCHANGE ACT
SUITE
BRODY
WILSHIRE BLVD
WEISS
LAW OFFICES
FERMAGLICH
BUSINESS
PARTY
CONSOLIDATION
JOHN WIRFEL
YORK
MICHAEL
FLOOR
TRINKO
CURTIS
SAVETT

 1 Jordan L. Lurie (130013)
      Mark A. Gordon (160113)
 2 WEISS & YOURMAN
      10940 Wilshire Blvd., 24th Floor
 3 Los Angeles, CA 90024
      (310) 208-2800
 4 (310) 209-2348 - fax
 5 Michael D. Braun (167416)
      Patrice L. Bishop (182256)
 6 STULL, STULL & BRODY
      10940 Wilshire Blvd. Suite 2300
 7 Los Angeles, CA 90024
      (310) 209-2468
 8 (310) 209-2087 - fax
 9 Jules Brody
      STULL, STULL & BRODY
10 6 East 45th Street
      New York, NY 10017
11 (212) 687-7320
      (212) 490-2022 - fax
12 Counsel for Movants, Proposed Lead Class Counsel
13
14                                    UNITED STATES DISTRICT COURT
15                                 NORTHERN DISTRICT OF CALIFORNIA
16                                              SAN JOSE DIVISION
17
18 PLUMBERS & PIPEFITTERS LOCAL 572                          ) CASE NO.: CV 01-20418 JW
      PENSION FUND, On Behalf of Itself and All              )
19 Others Similarly Situated,                                ) CLASS ACTION
                                                             )
20                            Plaintiff,                     ) NOTICE OF RESCHEDULING OF
                                                             ) MOTION FOR APPOINTMENT OF
21                    v.                                     ) WARREN FERMAGLICH, CHANNA
                                                             ) FERMAGLICH AND JOHN WIRFEL AS
22 CISCO SYSTEMS, INC., JOHN T.                              ) LEAD  PLAINTIFFS PURSUANT TO
      CHAMBERS, LARRY R. CARTER, GARY J. ) SECTION 21D OF THE SECURITIES
23 DAICHENDT, JUDITH L. ESTRIN, CHARLES ) EXCHANGE ACT OF 1934, TO
      H. GIANCARLO, MARIO MAZZOLA, CARL ) APPROVE LEAD PLAINTIFF'S CHOICE
24 REDFIELD, MICHELANGELO VOLPI,                             ) OF COUNSEL, AND FOR
      CAROL A. BARTZ, JAMES F. GIBBONS,                      ) CONSOLIDATION OF ALL RELATED
25 STEVEN M. WEST, EDWARD R. KOZEL and ) ACTIONS
      ROBERT L. PUETTE,                                      )
26                                                           ) Old Date:        September 17, 2001
                              Defendants.                    ) New Date:        September 10, 2001
27                                                           ) Time:            9:00 a.m.
                                                                  Ctrm:         8, Hon. James Ware
28

                                                             1

SNIPPETS:

10940 Wilshire Blvd., 24th Floor

Los Angeles, CA 90024

STULL, STULL & BRODY

New York, NY 10017

12 Counsel for Movants, Proposed Lead Class Counsel

Plumbers & Pipefitters Local 572 v. Cisco Systems, Inc., et al., Case No. CV-01-20418 JW

John Wirfel for Appointment as Lead Plaintiff Pursuant to Section 21D of the Securities

Act of 1934; to Approve Lead Plaintiffs' Choice of Counsel; and for Consolidation of all

South First St., San Jose, California.

not a party to the within action; my business address is 10940 Wilshire Blvd., 24th Floor,

FERMAGLICH, CHANNA FERMAGLICH AND JOHN WIRFEL AS LEAD PLAINTIFFS PURSUANT TO SECTION 21D OF

I am aware that on motion of the party served, service is presumed invalid if postal

600 West Broadway Suite 1800

MILBERG WEISS BERSHAD

Michael R.R. Reese

21 SAVETT FRUTKIN PODELL & RYAN P.C.

LAW OFFICES OF CURTIS V. TRINKO,

13 . STATEMENT OF NONOPPOSITION TO MOTION TO CONSOLIDATE

EXTRACTED KEY WORDS

CISCO
MOTION
DEFENDANT
BAR
HALL
CISCO INVESTORS GROUP
NONOPPOSITION
DEFENDANT PRICEWATERHOUSECOOPERS
MCAULIFFE LLP
FERMAGLICH
PWC
CISCO SYSTEMS
HELLER EHRMAN WHITE
CLASS CERTIFICATION PROCEEDINGS
SUBSEQUENT CLASS CERTIFICATION
PLAINTIFF
BONA FIDES
RIGHTS
RESERVES
RADIANT ADVISORS LLC
GIORGIO VANZINI
JOHN WIRFEL
CHANNA FERMAGLICH
WARREN FERMAGLICH
ROBERT RADWAY
SUNITA REDDY
COUNSEL
PREJUDICE
CONSOLIDATION ORDER

1     NORMAN J. BLEARS (Bar No. 95600)
      GEORGE H. BROWN (Bar No. 138590)
2     HELLER EHRMAN WHITE & McAULIFFE LLP
      275 Middlefield Road
3     Menlo Park, CA  94025-3506
      Telephone: (650) 324-7000
4     Facsimile: (650) 324-0638
5     MICHAEL L. RUGEN (Bar No. 85578)
      NICOLE M. RYAN (Bar No. 175980)
6     HELLER EHRMAN WHITE & McAULIFFE LLP
      333 Bush Street
7     San Francisco, California  94104-2878
      Telephone: (415) 772-6000
8     Facsimile: (415) 772-6268
9     Attorneys for Defendant
      PRICEWATERHOUSECOOPERS LLP
10
11                                 UNITED STATES DISTRICT COURT
12                               NORTHERN DISTRICT OF CALIFORNIA
13                                          SAN JOSE DIVISION
14    PLUMBERS  & PIPEFITTERS LOCAL                       No. C-01-20418-JW
15    572 PENSION FUND, On Behalf of Itself
      and All Others Similarly Situated,                  DEFENDANT
16                                                        PRICEWATERHOUSECOOPERS
                                            Plaintiff,    LLP'S STATEMENT OF
17                                                        NONOPPOSITION TO MOTION
            v.                                            TO CONSOLIDATE RELATED
18                                                        ACTIONS
      CISCO SYSTEMS, INC., et al.,
19                                                        The Honorable James Ware
                                      Defendants,
20                                                        Date:   September 10, 2001
                                                          Time:   9:00 a.m.
21                                                        Place:  Courtroom 8
22

23

24

25

26

27

28

      DEFENDANT PRICEWATERHOUSECOOPERS LLP'S

SNIPPETS:

NORMAN J. BLEARS (Bar No. 95600)

HELLER EHRMAN WHITE & McAULIFFE LLP

DEFENDANT PRICEWATERHOUSECOOPERS LLP'S STATEMENT OF NONOPPOSITION TO MOTION TO CONSOLIDATE

and Exchange Act of 1934 brought by the Cisco Investors Group.

to consolidate, Hall v. Cisco Systems, Inc., C-01-20643-JW.1 PwC has no objection to the

consolidation of Hall with the other sixteen actions, so long as any consolidation order is

tailored not to prejudice PwC's interests.

counsel brought by the Cisco Investors Group, Sunita Reddy, Robert Radway and the Cisco

10 Institutional Shareholder's Group, Warren Fermaglich, Channa Fermaglich and John Wirfel,

11 Giorgio Vanzini, and Radiant Advisors LLC, although it reserves its rights to challenge the

12 bona fides of any plaintiff with respect to any subsequent class certification proceedings.

14 . REPLY TO THE LEAD PLAINTIFF OPPOSITIONS

EXTRACTED KEY WORDS

PLAINTIFFS
INVESTORS GROUP
CISCO INVESTORS
APPOINT
COURT
INDIVIDUAL INVESTOR
SUPPORT THEREOF
CO-LEAD PLAINTIFFS
LLC
ADVISORS
RADIANT
MPA
LEAD PLTF OPPS
COUNSEL
FERMAGLICH
INSTITUTIONAL INVESTOR
MOVING
STULL
PAPERS
OPPOSITION
LOS ANGELES
BRODY
ZALTZMAN
COMPETING
LOSSES
REPRESENTATION
OXFORD
SECURITIES CLASS ACTION
MOTION

 1 STULL, STULL & BRODY
      Michael D. Braun (167416)
 2 Patrice L. Bishop (182256)
      10940 Wilshire Blvd. Suite 2300
 3 Los Angeles, CA 90024
      (310) 209-2468
 4 (310) 209-2087 - fax

 5 Counsel for Movant, Proposed Lead Class Counsel

 6 WEISS & YOURMAN
      Jordan L. Lurie (130013)
 7 Mark A. Gordon (160113)
      10940 Wilshire Blvd., 24th Floor
 8 Los Angeles, CA 90024
      (310) 208-2800
 9 (310) 209-2348 - fax

10 STULL, STULL & BRODY
      Jules Brody
11 Howard T. Longman
      6 East 45th Street
12 New York, NY 10017
      (212) 687-7320
13 (212) 490-2022 - fax

14 Attorneys for Plaintiffs

15                                 UNITED STATES DISTRICT COURT

16                                NORTHERN DISTRICT OF CALIFORNIA

17                                         SAN JOSE DIVISION

18

19 PLUMBERS & PIPEFITTERS LOCAL 572                ) CASE NO.: CV 01-20418 JW
      PENSION FUND, On Behalf of Itself and All    )
20 Others Similarly Situated,                      ) CLASS ACTION
                                                   )
21                          Plaintiff,             ) WARREN FERMAGLICH'S REPLY TO
                                                   ) THE LEAD PLAINTIFF OPPOSITIONS
22                   v.                            ) OF THE CISCO INVESTORS GROUP
                                                   ) AND RADIANT ADVISORS, LLC;
23 CISCO SYSTEMS, INC., JOHN T.                    ) MEMORANDUM OF POINTS AND
      CHAMBERS, LARRY R. CARTER, GARY J. ) AUTHORITIES IN SUPPORT THEREOF
24 DAICHENDT, JUDITH L. ESTRIN, CHARLES )
      H. GIANCARLO, MARIO MAZZOLA, CARL ) Date: September 10, 2001
25 REDFIELD, MICHELANGELO VOLPI,                   ) Time: 9:00 a.m.

SNIPPETS:

STULL, STULL & BRODY

Los Angeles, CA 90024

Counsel for Movant, Proposed Lead Class Counsel

WARREN FERMAGLICH'S REPLY TO THE LEAD PLTF OPPS.

OF THE CISCO INVESTORS GROUP AND RADIANT ADVISORS, LLC; MPA IN SUPPORT THEREOF

Mr. Fermaglich, as outlined in his moving and

opposing papers, lost over $7.9 million in his Cisco investments during the Class Period.

to all the information submitted by the proposed lead plaintiffs, Mr. Fermaglich has the

16 institutional investor and an individual investor, the Court should appoint Mr. Fermaglich

17 individual investor lead plaintiff because he has the largest loss of any moving

In its opposition,

In re Oxford Health Plans,

representation,

13 lead plaintiffs refused to appoint an attorney-created group in its entirety,

15 Courts selected co-lead plaintiffs from competing moving papers.

For example, in Zaltzman, 1998

20 institutional investor and two individuals with the largest losses as co-lead plaintiffs.

I am aware that on motion of the party served, service is presumed invalid if postal

16 the following electronic mail address provided by the Securities Class Action

15 . DECLARATION OF WARREN FERMAGLICH

EXTRACTED KEY WORDS

COUNSEL
CISCO
FERMAGLICH
INVESTMENT
CLASS PERIOD
SUPPORT
STULL
MONITOR
APPT
DECL
CISCO SYSTEMS
PLUMBERS
BRODY
WILLINGNESS
CERTIFICATION
OMISSIONS
PURCHASE
WIFE
SECURITIES
APPOINTMENT
DECLARE
APPROVE LEAD PLAINTIFFS
EXCHANGE ACT
LOS ANGELES
WILSHIRE BLVD
CLASS MEMBERS
DUTY
LITIGATION
ADEQUATE COUNSEL

 1 STULL, STULL & BRODY
      Michael D. Braun (167416)
 2 Patrice L. Bishop (182256)
      10940 Wilshire Blvd. Suite 2300
 3 Los Angeles, CA 90024
      (310) 209-2468
 4 (310) 209-2087 - fax
 5 Counsel for Movant, Proposed Lead Class Counsel
 6 WEISS & YOURMAN
      Jordan L. Lurie (130013)
 7 Mark A. Gordon (160113)
      10940 Wilshire Blvd., 24th Floor
 8 Los Angeles, CA 90024
      (310) 208-2800
 9 (310) 209-2348 - fax
10 STULL, STULL & BRODY
      Jules Brody
11 Howard T. Longman
      6 East 45th Street
12 New York, NY 10017
      (212) 687-7320
13 (212) 490-2022 - fax
14 Attorneys for Plaintiffs
15                                         UNITED STATES DISTRICT COURT
16                                      NORTHERN DISTRICT OF CALIFORNIA
17                                                     SAN JOSE DIVISION
18
19 PLUMBERS & PIPEFITTERS LOCAL 572                                    ) CASE NO.: CV 01-20418 JW
      PENSION FUND, On Behalf of Itself and All                        )
20 Others Similarly Situated,                                          ) CLASS ACTION
                                                                       )
21                                 Plaintiff,                          ) DECLARATION OF WARREN
                                                                       ) FERMAGLICH IN SUPPORT OF
22                       v.                                            ) MOTION FOR APPOINTMENT OF
                                                                       ) LEAD PLAINTIFF PURSUANT TO
23 CISCO SYSTEMS, INC., JOHN T.                                        ) SECTION 21D OF THE
      CHAMBERS, LARRY R. CARTER, GARY J. ) EXCHANGE ACT OF 1934; TO
24 DAICHENDT, JUDITH L. ESTRIN, CHARLES ) APPROVE LEAD PLAINTIFFS' CHOICE
      H. GIANCARLO, MARIO MAZZOLA, CARL ) OF COUNSEL; AND FOR
25 REDFIELD, MICHELANGELO VOLPI,                                       ) CONSOLIDATION OF ALL
      CAROL A. BARTZ, JAMES F. GIBBONS,                                ) ACTIONS
26 STEVEN M. WEST, EDWARD R. KOZEL and )
      ROBERT L. PUETTE,                                                ) Date: September 10, 2001
27                                                                     ) Time: 9:00 a.m.
                                   Defendants.                         ) Ctrm: 8, Hon. James Ware
28                                                                     )

                                                                      1
      Plumbers & Pipefitters Local 572 v. Cisco Systems, Inc., et al., Case No. CV-01-20418 JW

SNIPPETS:

STULL, STULL & BRODY

Los Angeles, CA 90024

Counsel for Movant, Proposed Lead Class Counsel

10940 Wilshire Blvd., 24th Floor

Plumbers & Pipefitters Local 572 v. Cisco Systems, Inc., et al., Case No. CV-01-20418 JW

DECL.

OF W. FERMAGLICH N SUPPORT OF APPT.

I, Warren Fermaglich, declare:

support of my motion for "Appointment as Lead Plaintiff Pursuant to Section 21D of the

Exchange Act of 1934; to Approve Lead Plaintiffs' Choice of Counsel; and for Consolidation of

Cisco options on behalf of myself and my wife,

Our investment in Cisco was approximately 90 to 95%

13 every decision to purchase Cisco stock.

14 me in the market place during the Class Period.

18 willingness to be a lead plaintiff.

20 lost at least $7,992,520.80 due to defendants' omissions and/or misrepresentations.

27 adequate counsel and monitor that counsel and this litigation.

and that I have a fiduciary duty to those individuals and/or entities.

Class certification on behalf of myself and the Class members.

16 . MOTION FOR APPOINTMENT

EXTRACTED KEY WORDS

MOVANTS
COUNSEL
CISCO SYSTEMS
SECURITIES
LEAD PLAINTIFF
PLUMBERS
EXCHANGE ACT
STULL
GORDON
MOTION
BRODY
CONSOLIDATION
APPOINTMENT
APPROVE LEAD
YOURMAN
CLASS MEMBERS
CLASS PERIOD
DEFENDANTS
CISCO STOCK
RELATED ACTIONS
MEMORANDUM
LOS ANGELES
WILSHIRE BLVD
APPOINTED LEAD PLAINTIFF
GORDON DECL
FEDERAL SECURITIES LAWS
FEDERAL RULES
PLAINTIFF PURSUANT
CLASS REPRESENTATIVES

 1 Jordan L. Lurie (130013)
      Mark A. Gordon (160113)
 2 WEISS & YOURMAN
      10940 Wilshire Blvd., 24th Floor
 3 Los Angeles, CA 90024
      (310) 208-2800
 4 (310) 209-2348 - fax
 5 Michael D. Braun (167416)
      Patrice L. Bishop (182256)
 6 STULL, STULL & BRODY
      10940 Wilshire Blvd. Suite 2300
 7 Los Angeles, CA 90024
      (310) 209-2468
 8 (310) 209-2087 - fax
 9 Jules Brody
      STULL, STULL & BRODY
10 6 East 45th Street
      New York, NY 10017
11 (212) 687-7320
      (212) 490-2022 - fax
12 Counsel for Movants, Proposed Lead Class Counsel
13
14                                    UNITED STATES DISTRICT COURT
15                                 NORTHERN DISTRICT OF CALIFORNIA
16                                              SAN JOSE DIVISION
17
18 PLUMBERS & PIPEFITTERS LOCAL 572                          ) CASE NO.: CV 01-20418 JW
      PENSION FUND, On Behalf of Itself and All              )
19 Others Similarly Situated,                                ) CLASS ACTION
                                                             )
20                            Plaintiff,                     ) NOTICE OF MOTION AND MOTION
                                                             ) FOR APPOINTMENT OF WARREN
21                    v.                                     ) FERMAGLICH, CHANNA
                                                             ) FERMAGLICH AND JOHN WIRFEL AS
22 CISCO SYSTEMS, INC., JOHN T.                              ) LEAD  PLAINTIFFS PURSUANT TO
      CHAMBERS, LARRY R. CARTER, GARY J. ) SECTION 21D OF THE SECURITIES
23 DAICHENDT, JUDITH L. ESTRIN, CHARLES ) EXCHANGE ACT OF 1934, TO
      H. GIANCARLO, MARIO MAZZOLA, CARL ) APPROVE LEAD PLAINTIFF'S CHOICE
24 REDFIELD, MICHELANGELO VOLPI,                             ) OF COUNSEL, AND FOR
      CAROL A. BARTZ, JAMES F. GIBBONS,                      ) CONSOLIDATION OF ALL RELATED
25 STEVEN M. WEST, EDWARD R. KOZEL and ) ACTIONS; MEMORANDUM OF POINTS
      ROBERT L. PUETTE,                                      ) AND AUTHORITIES IN SUPPORT
26                                                           ) THEREOF
                              Defendants.                    )
27                                                           ) Date: July 30, 2001
                                                                  Time: 9:00 a.m.
28                                                                Ctrm: 8, Hon. James Ware

                                                             1

SNIPPETS:

Jordan L. Lurie Mark A. Gordon

10940 Wilshire Blvd., 24th Floor

Los Angeles, CA 90024

STULL, STULL & BRODY

12 Counsel for Movants, Proposed Lead Class Counsel

CHAMBERS, LARRY R. CARTER, GARY J.) SECTION 21D OF THE SECURITIES 23 DAICHENDT, JUDITH L.

EDWARD R. KOZEL and) ACTIONS; MEMORANDUM OF POINTS

Plumbers & Pipefitters Local 572 v. Cisco Systems, Inc., et al., Case No. CV-01-20418 JW

Channa Fermaglich and John Wirfel (collectively "Movants") will, and hereby do, move this

for an order granting Movants' motion for "Appointment as Lead Plaintiff Pursuant to Section

Consolidation of all Related Actions".

Movants meet the requirements of Rule 23 of the Federal Rules of Civil Procedure for

13 their selection of Weiss & Yourman and Stull, Stull & Brody, two law firms which have

their motion for "Appointment as Lead Plaintiff Pursuant to Section 21D of the Securities

Act of 1934; to Approve Lead Plaintiffs' Choice of Counsel; and for Consolidation of all

actions allege the same common scheme and course of conduct by defendants to defraud

See Exhibits A and B to the Gordon Decl.

22 the selection of Lead Plaintiffs to oversee class actions brought under the federal

27 have completed sworn certifications listing their purchases of Cisco stock and requesting

11 Wire which informed potential class members of the pendency of the action and their right

Class Period, and have incurred losses of more than $9,443,000.

serve as, and assume the responsibilities of, class representatives.

17 . DECLARATION OF MARK A

EXTRACTED KEY WORDS

COUNSEL
STULL
GORDON
SUPPORT
LEAD PLAINTIFF
PLUMBERS
MOVANTS
BRODY
JOHN
FERMAGLICH
DECLARE
LEAD PLFS
APPT
DECL
CISCO SYSTEMS
CONSOLIDATION
EXCHANGE ACT
SECURITIES
LEAD PLAINTIFF PURSUANT
LOS ANGELES
WILSHIRE BLVD
MARK
YOURMAN
WEISS
FOREGOING
AMERICA
SLIP
AURORA FOODS
STEINER

 1 WEISS & YOURMAN
      JORDAN L. LURIE (130013)
 2 MARK A. GORDON (160113)
      10940 Wilshire Blvd., 24th Floor
 3 Los Angeles, CA 90024
      (310) 208-2800
 4 (310) 209-2348 - fax
 5 STULL, STULL & BRODY
      MICHAEL D. BRAUN (167416)
 6 PATRICE L. BISHOP (182256)
      10940 Wilshire Blvd. Suite 2300
 7 Los Angeles, CA 90024
      (310) 209-2468
 8 (310) 209-2087 - fax
 9 STULL, STULL & BRODY
      JULES BRODY
10 6 East 45th Street
      New York, NY 10017
11 (212) 687-7320
      (212) 490-2022 - fax
12 Counsel for Movants, Proposed Lead Class Counsel
13
14                                    UNITED STATES DISTRICT COURT
15                                  NORTHERN DISTRICT OF CALIFORNIA
16                                              SAN JOSE DIVISION
17
18 PLUMBERS & PIPEFITTERS LOCAL 572 ) CASE NO.: CV 01-20418 JW
19 PENSION FUND, On Behalf of Itself and All                 )
      Others Similarly Situated,                             ) CLASS ACTION
20                                                           )
                              Plaintiff,                     ) DECLARATION OF MARK A. GORDON
21                                                           ) IN SUPPORT OF MOTION FOR
                      v.                                     ) APPOINTMENT OF WARREN
22                                                           ) FERMAGLICH, CHANNA
      CISCO SYSTEMS, INC., JOHN T.                           ) FERMAGLICH AND JOHN WIRFEL AS
23 CHAMBERS, LARRY R. CARTER, GARY J. ) LEAD PLAINTIFF PURSUANT TO
      DAICHENDT, JUDITH L. ESTRIN, CHARLES ) SECTION 21D OF THE SECURITIES
24 H. GIANCARLO, MARIO MAZZOLA, CARL ) EXCHANGE ACT OF 1934; TO
      REDFIELD, MICHELANGELO VOLPI,                          ) APPROVE LEAD PLAINTIFFS' CHOICE
25 CAROL A. BARTZ, JAMES F. GIBBONS,                         ) OF COUNSEL; AND FOR
      STEVEN M. WEST, EDWARD R. KOZEL and ) CONSOLIDATION OF ALL RELATED
26 ROBERT L. PUETTE,                                         ) ACTIONS
                                                             )
27                            Defendants.                    ) Date: July 30, 2001
                                                             ) Time: 9:00 a.m.
28                                                                Ctrm:: 8, Hon. James Ware

                                                             1
      Plumbers & Pipefitters Local 572 v. Cisco Systems, Inc., et al., Case No. CV-01-20418 JW

SNIPPETS:

10940 Wilshire Blvd., 24th Floor

Los Angeles, CA 90024

STULL, STULL & BRODY MICHAEL D. BRAUN

STULL & BRODY JULES BRODY

12 Counsel for Movants, Proposed Lead Class Counsel

18 PLUMBERS & PIPEFITTERS LOCAL 572) CASE NO.:

Plumbers & Pipefitters Local 572 v. Cisco Systems, Inc., et al., Case No. CV-01-20418 JW

DECL.

OF M. GORDON IN SUPPORT OF APPT AS LEAD PLFS

I, Mark A. Gordon, declare:

I am an associate with the law firm of Weiss & Yourman,

Warren Fermaglich, Channa Fermaglich and John Wirfel.

support of Movants' motion for "Appointment as Lead Plaintiff Pursuant to Section 21D of the

Securities Exchange Act of 1934; to Approve Lead Plaintiffs' Choice of Counsel; and for

Consolidation of all Related Actions".

Exhibit E: Powers v. Eichen,

Steiner v. Aurora Foods, Inc., et al., No. C-00-602-CW, slip op

23 States of America that the foregoing is true and correct.

18 . COMPLAINT B 10

EXTRACTED KEY WORDS

CHAMBERS
CISCO SYSTEMS
DEFENDANT
SALES
CLASS PERIOD
REVENUE
JOHN
CISCO STOCK
DEMAND
CARTER
ACQUISITIONS
GROWTH
CUSTOMERS
MARKET
INVENTORY
ARTIFICIALLY INFLATED PRICES
NET INCOME
SECURITIES
SERVICE PROVIDERS
EPS
CONFIDENTIAL CISCO INFORMATION
CALIFORNIA
UNITED STATES
INVENTORIES
VENDOR FINANCING
TECHNOLOGY
CARL REDFIELD
SENIOR VICE PRESIDENT-FINANCE
SUBSTANTIAL TECHNICAL DEFECTS



   MILBERG WEISS BERSHAD
   HYNES & LERACH LLP
   WILLIAM S. LERACH (68581)
   DARREN J. ROBBINS (168593)
   SPENCER A. BURKHOLZ (147029)
   DANIEL S. DROSMAN (200643)
   FREDERICK B. BURNSIDE (211089)
   600 West Broadway, Suite 1800
   San Diego, CA 92101
   Telephone: 619/231-1058
   619/231-7423 (fax)

   BULL & LIFSHITZ, LLP
   JOSHUA M. LIFSHITZ
   246 West 38th Street
   New York, NY 10018
   Telephone: 212-869-9449
   212/869-5632 (fax)

   Attorneys for Plaintiff

                        UNITED STATES DISTRICT COURT

                      NORTHERN DISTRICT OF CALIFORNIA



   SAMUEL MAYER, On Behalf of
   Himself and All Others Similarly Situated,

                           Plaintiff,

       vs.

   CISCO SYSTEMS, INC., JOHN T.
   CHAMBERS, LARRY R. CARTER, GARY
   J. DAICHENDT, JUDITH L. ESTRIN,
   CHARLES H. GIANCARLO, MARIO
   MAZZOLA, CARL REDFIELD,
   MICHELANGELO VOLPI, CAROL A.
   BARTZ, JAMES F. GIBBONS, STEVEN
   M. WEST, EDWARD R. KOZEL
   and ROBERT L. PUETTE,

                           Defendants.
   ____________________________________

SNIPPETS:

COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS

DEMAND FOR JURY TRIAL

This is a securities fraud class action on behalf of persons who purchased Cisco Systems,

By the beginning of the Class Period in 8/99, Internet Service Providers and competitive

Through this manipulation and the shipment of defective or incomplete products, as well as

The inflation in Cisco's stock price was essential to its main corporate strategy - that of

In addition, each of the defendants had the motive and the opportunity to perpetrate the

Defendants' misconduct has wiped out over $400 billion in market capitalization as Cisco

Defendant Cisco maintains its headquarters at San Jose, California.

Defendant John T. Chambers was, during the Class Period, President, Chief Executive Officer,

During the Class Period, while in possession of confidential Cisco information, Chambers sold