Rupa Marya v. Warner Chappell Music Inc

Filing 150

Joint STIPULATION to Continue Scheduling Order Deadlines from per joint stipulation to per joint stipulation Re: Scheduling Conference, Set/Reset Deadlines/Hearings,,,,,,,,,,,, 92 filed by plaintiffs Good Morning to You Productions Corp, Majar Productions LLC, Rupa Marya, Robert Siegel. (Attachments: # 1 Declaration of Betsy C. Manifold, # 2 Proposed Order)(Manifold, Betsy)

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DECLARATION OF BETSY C. MANIFOLD 1 2 1. I, Betsy C. Manifold, hereby declare as follows: 3 2. I am an attorney duly licensed to practice law in the states of Wisconsin, 4 New York, and California, and am admitted to the bar of this Court. I am a partner at 5 the law offices of Wolf Haldenstein Adler Freeman & Herz LLP, interim lead class 6 counsel for plaintiffs, Good Morning To You Prodcutions Corp., Robert Siegel, Rupa 7 Marya d/b/a/ Rupa & The April Fishes, and Majar Productions LLC (“Plaintiffs”), in 8 the above-captioned action. I make this declaration in support of the parties’ joint 9 stipulation to extend scheduling order deadlines and have personal knowledge of the 10 facts stated herein. 11 competently do so. 12 13 14 3. If called upon to testify as to them, I could, and would, On July 24, 2014, Plaintiffs timely served their Expert Disclosures on all parties in the action. 4. Plaintiffs’ designated expert, Mr. Joel Sachs, advised counsel for 15 Plaintiffs that he will be unavailable for deposition from August 11, 2014, up to and 16 including August 25, 2014, due to a pre-paid, pre-planned, trip out of the country. 17 5. Defendants’ counsel advised that they wish to depose Mr. Sachs prior to 18 the August 25th deadline to designate rebuttal experts imposed by the Court’s 19 Scheduling Order (Dkt. 92). 20 6. Plaintiffs’ counsel has an unavoidable scheduling conflict in October 21 and Defendants’ counsel agreed to extend the joint briefing on the parties’ motion for 22 summary judgment to accommodate said conflict subject to the Court’s approval. 23 7. No prior extension of the following deadlines has been sought by any 24 party and as such, the parties met and conferred in good faith to agree upon the 25 following extension of dates imposed under the Court’s Scheduling Order (Dkt. 92): 26 Rebuttal Expert Disclosures: September 15, 2014 27 Expert Discovery Motions Deadline: October 3, 2014 28 Expert Discovery Cut-Off: October 13, 2014 -6- 1 File Joint Status Report: 2 File Joint Motion for Summary 3 4 October 13, 2014 Judgment: 8. November 21, 2014. For the foregoing reasons, Plaintiffs have shown good cause for the 5 brief extension to the Scheduling Order deadlines, and respectfully request the Court 6 enter an amended scheduling order based upon the parties’ proposed dates in their 7 joint stipulation submitted concurrently herewith. 8 I declare under penalty of perjury that the foregoing is true and correct. 9 Executed this 14th day of August 2014, in San Diego, California. 10 /s/Betsy C. Manifold BETSY C. MANIFOLD 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 WARNER/CHAPPELL:21051v2.stipulation 28 -7-

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