michael l. rugen (bar no. 85578) carol lynn thompson...

RYAN DECLARATION IN SUPPORT OF DEF. PWC’S MOTION FOR SUMMARY JUDGMENT ON LOSS CAUSATION AND DAMAGES CASE NO. C-01-20418-JW

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MICHAEL L. RUGEN (Bar No. 85578) CAROL LYNN THOMPSON (Bar No. 148079) NICOLE M. RYAN (Bar No. 175980) HELLER EHRMAN LLP 333 Bush Street San Francisco, CA 94105-2878 Telephone: (415) 772-6000 Facsimile: (415) 772-6268 [email protected] [email protected] [email protected] NORMAN J. BLEARS (Bar No. 95600) DANIEL T. ROCKEY (Bar No. 178604) HELLER EHRMAN LLP 275 Middlefield Road Menlo Park, CA 94025-3506 Telephone: (650) 324-7000 Facsimile: (650) 324-0638 [email protected] [email protected] Attorneys for Defendant PRICEWATERHOUSECOOPERS LLP

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

In re CISCO SYSTEMS INC. SECURITIES LITIGATION

This Document Relates To: ALL ACTIONS

No. C-01-20418-JW (PVT) CLASS ACTION DECLARATION OF NICOLE M. RYAN IN SUPPORT OF DEFENDANT PRICEWATERHOUSE-COOPERS LLP’S MOTION FOR SUMMARY JUDGMENT ON LOSS CAUSATION AND DAMAGES The Honorable James Ware Date: June 12, 2006 Time: 9:00 a.m. Courtroom 8, Fourth Floor Trial Date: October 4, 2006

Case 5:01-cv-20418-JW Document 459 Filed 03/13/2006 of 3

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RYAN DECLARATION IN SUPPORT OF PWC’S MOTION FOR SUMMARY JUDGMENT RE: LOSS CAUSATION CASE NO. C-01-20418-JW

I, Nicole M. Ryan, declare as follows:

1. I am an attorney at law, licensed to practice before the courts of the State of

California, and am employed by Heller Ehrman LLP, attorneys of record for

PricewaterhouseCoopers LLP (“PwC”). I have personal knowledge of the matters set forth herein,

unless otherwise indicated, and if called as a witness, I could and would competently testify thereto.

2. I submit this Declaration in support of PwC’s Motion for Summary Judgment on

Loss Causation and Damages.

3. Attached as exhibits hereto are true and correct copies of the following:

A: Selected pages of the Form 10-K filed by Cisco Systems, Inc. for the period ending July 29, 2000, together with authenticating deposition testimony.

B: A February 6, 2001 Dow Jones Newswires Report entitled “Cisco Systems CEO Cites Economic Slowdown For Soft 2Q,” together with relevant deposition testimony.

C: Selected pages from the board packet distributed in connection with Cisco’s November 14, 2000 Board of Directors Meeting, together with authenticating deposition testimony.

D: Selected pages from the board packet distributed in connection with Cisco’s January 9, 2001 Board of Directors Meeting, together with authenticating deposition testimony.

E: Selected pages from the board packet distributed in connection with Cisco’s March 15, 2001 Board of Directors Meeting, together with authenticating deposition testimony.

F: Selected pages from the Expert Report of Blaine F. Nye, Ph.D, dated October 17, 2005.

G: The Rebuttal Expert Report of Blaine F. Nye, Ph.D., dated December 14, 2005, exclusive of appendices and exhibits.

H: The Expert Report of Christopher M. James, dated November 30, 2005, exclusive of appendices and exhibits.

I: Selected pages from the Expert Report of Dr. Joseph S. Kraemer, dated January 11, 2006.

J: Selected pages from the transcript of the Expert Deposition of Blaine F. Nye, taken in this action on February 21, 2006.

K: Selected pages from the transcript of the Expert Deposition of Blaine F. Nye, taken in this action on February 22, 2006.


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RYAN DECLARATION IN SUPPORT OF PWC’S MOTION FOR SUMMARY JUDGMENT RE: LOSS CAUSATION CASE NO. C-01-20418-JW

L: Selected pages from the transcript of the Deposition of Larry Carter, taken in this action on September 29, 2005.

M: Selected pages from the transcript of the Deposition of Larry Carter, taken in this action on September 30, 2005.

N: Selected pages from the transcript of the Deposition of John C. Murphy, taken in this action on September 4, 2003.

O: An article from the publication Compliance Week, entitled “Restatements Should Subside As 404, Lease Issues Fade,” and dated February 14, 2006.

I declare under penalty of perjury that the foregoing is true and correct. Executed this 13th

day of March 2006, in San Francisco, California.

By: __/s/ _____________

Nicole M. Ryan


Case 5:01-cv-20418-JW Document 459 Filed 03/13/2006 Page 1 of 9

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