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