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