Rupa Marya v. Warner Chappell Music Inc

Filing 34

[DOCUMENT STRICKEN PURSUANT TO ORDER G-112-B] - STIPULATION to Consolidate Cases as to CV13-05164-GHK with Lead Case CV13-04460-GHK filed by plaintiffs Good Morning to You Productions Corp, Rupa Marya. (Attachments: # 1 Declaration of Betsy C. Manifold In Support of Thereof, # 2 Proposed Order Thereon)(Manifold, Betsy) Modified on 8/28/2013 (shb).

Download PDF
DECLARATION OF BESTY C. MANIFOLD 1 2 I, Betsy C. Manifold, hereby declare: 3 1. I am an attorney duly licensed to practice law in the states of 4 California, Wisconsin, and New York; and am a partner at the law firm of Wolf 5 Haldenstein Adler Freeman & Herz LLP, counsel of record for plaintiffs Good 6 Morning To You Productions Corp., Robert Siegel, and Rupa Marya. I have 7 personal knowledge of the facts stated herein and if called upon to testify as to them, 8 I could, and would, competently do so. 9 2. The parties have met and conferred, and agreed that Plaintiffs shall, 10 within two (2) days of the filing of this stipulation, hand-serve or electronically 11 deliver to Defendants’ counsel a Consolidated Second Amended Class Action 12 Complaint, solely to conform the allegations and claims in the Consolidated First 13 Amended Class Action Complaint and the complaint in the Majar Action to each 14 other, as provided by this stipulation; and Plaintiffs shall, within two (2) days of the 15 entry of the Order on this stipulation, file the Consolidated Second Amended Class 16 Action Complaint, unless otherwise ordered by the Court. 17 3. The parties have met and conferred and agreed that, because the 18 Consolidated Second Amended Class Action Complaint will not make any 19 substantive changes to the allegations or claims as previously filed in the 20 Consolidated First Amended Class Action Complaint or the complaint in the Majar 21 Action, the schedule established by the Court’s Consolidation Order for Defendant 22 Warner/Chappell’s response to the Consolidated Complaint should remain 23 unchanged, such that Defendants Warner/Chappell and Summy’s response to the 24 Consolidated Second Amended Class Action Complaint should be as per that 25 Consolidation Order. 26 /// 27 /// 28 /// 21434065.1 -1- 1 2 I declare under penalty of perjury that the foregoing is true and correct. Executed this 14th day of August, 2013, in San Diego, California. 3 4 By: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- /s/ Betsy C. Manifold BETSY C. MANIFOLD

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?