George Clinton v. Will Adams et al

Filing 64

STIPULATION for Order for voluntary stay of discovery between certain parties filed by Plaintiff George Clinton. (Attachments: # 1 Proposed Order)(Thennisch, Jeffrey)

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JEFFREY P. THENNISCH (Michigan Bar Number P51499)
(appearing Pro Hac Vice)
[e-mail]
DOBRUSIN THENNISCH PC
29 West Lawrence Street, Suite 210
Pontiac, Michigan 48342
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff GEORGE CLINTON

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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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GEORGE CLINTON, an individual,
Case No. CV 10-09476-ODW-PLA

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Plaintiff,
The Honorable Otis D. Wright II

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v.
WILL ADAMS, p/k/a will,I,am
individually and d/b/a will.i.am music
publishing , et al.,

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STIPULATED REQUEST FOR
VOLUNTARY STAY OF
DISCOVERY BETWEEN
CERTAIN PARTIES UNTIL
OCTOBER 31, 2011

Defendants.
Action Filed: December 10, 2010

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- 1 –
Stipulation

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Plaintiff, George Clinton (hereinafter ”CLINTON”), and the following

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Defendants, WILL ADAMS (sued as Will Adams, p/k/a will.i.am, individually and

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d/b/a WILL.I.AM MUSIC PUBLISHING), ALLAN PINEDA (sued as Allan Pineda

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p/k/a apl.de.ap, individually and d/b/a JEEPNEY MUSIC PUBLISHING), JAIME

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GOMEZ (sued as Jamie Gomez, p/k/a Taboo, individually and d/b/a NAWASHA

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NETWORKS PUBLISHING), STACY FERGUSON (sued as Stacy Ferguson p/k/a

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Fergie), WILL I AM MUSIC, INC., a California corporation; and CHERRY LANE

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MUSIC PUBLISHING COMPANY, INC., a New York corporation; (hereinafter

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collectively the “Stipulating Defendants”), by and through their respective counsel of
record and pursuant to the Federal Rules of Civil Procedure, hereby request a

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voluntary stay of discovery and pending discovery responses between these parties
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until Monday, October 31, 2011, during which time the above-identified parties will
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engage in the voluntary exchange, disclosure, and dissemination of documents and
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information agreed to by the parties for the purpose of engaging in good faith
settlement discussions.
The above-identified parties further agree that this requested voluntary stay shall

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not include, encompass, or delay the deposition of a third party deponent named Eban

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Kelly, to take place in the Commonwealth of Virginia in October 2011, in order to

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preserve Mr. Kelly’s testimony. If requested by the Court, the above-identified parties

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shall jointly report the status of these good faith settlement discussions to the Court on

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or about October 31, 2011.

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So Stipulated And Approved:
s/ Jeffrey P. Thennisch
Jeffrey P. Thennisch (P51499)
Attorney for Plaintiff

So Stipulated And Approved:
s/Allen B.Grodsky(with consent)
Allen B. Grodsky (SBN 111064)
Attorney for Defendants
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Stipulation

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George Clinton
Dobrusin Thennisch, PC
29 West Lawrence Street, Suite 210
Pontiac, MI 48342
[phone]/[phone] (Fax)
[e-mail]

Will Adams p/k/a will.i.am et al.
Grodsky & Olecki LLP
2001 Wilshire Blvd., Suite 210
Santa Monica, CA 90403
[phone]/ [phone] (Fax)
[e-mail]

September 28, 2011

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September 28, 2011

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Stipulation