Rupa Marya v. Warner Chappell Music Inc

Filing 343

NOTICE OF MOTION AND MOTION to to be Excused from Appeaing at the 6-27-16 Hearing UNOPPOSED MOTION REQUESTING LEAVE FOR INTERVENERS TO BE EXCUSED FROM APPEARING filed by Interveners The Association for Childhood Education International, The Hill Foundation, Inc.. (Attachments: # 1 Proposed Order on Interveners' Unopposed Motion Requesting Leave to be Excused from Appearing) (Luskin, Scott)

SCOTT O. LUSKIN 238082
[e-mail]
PAYNE & FEARS
2
1100 Glendon Avenue, Suite 1250
3 Los Angeles, California 90024
Telephone: [phone]
4 Facsimile: [phone]
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STEVEN E. TILLER (pro hac vice)
[e-mail]
6 WHITEFORD, TAYLOR & PRESTON, LLP
7 St. Paul Street
7 Suite 1300
Baltimore, Maryland 21202-1636
8 Telephone: [phone]
Fax: [phone]
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Attorneys for Interveners,
The Association for Childhood Education International and
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The Hill Foundation, Inc.
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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RUPA MARYA, et. al.

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Plaintiffs,
vs.
WARNER/CHAPPELL MUSIC,
INC., et al.
Defendant.

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Case No. CV13-04460 GHK
(MRWx)
Assigned to Hon. George H. King
UNOPPOSED MOTION
REQUESTING LEAVE FOR
INTERVENERS TO BE EXCUSED
FROM APPEARING

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UNOPPOSED MOTION REQUESTING LEAVE
FOR INTERVENERS TO BE EXCUSED FROM APPEARING

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TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:

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The Parties are to appear before this Honorable Court on June 27, 2016

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for a Motions Hearing regarding the Final Approval of the Class Action and
Plaintiffs’ Counsel’s Motion for Attorneys’ Fees (the “Hearing”). Interveners,

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the Association for Childhood Education International (“ACEI”) and the Hill

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Foundation, Inc. (“Hill Foundation”), have not taken any position, nor do they

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intend on taking any position, on either motion. As both ACEI and the Hill

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Foundation are non-profit organizations, the cost that would be incurred by

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having counsel attend this Hearing would directly impact the organizations by

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diverting critical funds from their charitable operations. Accordingly, the
Intervenors respectfully request leave to be excused from appearing at the
Hearing. Counsel for Interveners will be available by telephone during the

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Hearing in the event the Court must reach them at the following numbers:
primarily at [phone] and, if unavailable at that number, then (443) 3479449.

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Counsel for Intervenors has contacted lead counsel for both Plaintiffs
(Mark Rifken) and Defendants (Kelly Klaus) who have no objection to this
Motion. Further, the Court granted a very similar request made on behalf of

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UNOPPOSED MOTION REQUESTING LEAVE
FOR INTERVENERS TO BE EXCUSED FROM APPEARING

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the Intervenors with regard to the Preliminary Hearing to Approve the Class

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Action.

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DATED: June 21, 2016

PAYNE & FEARS, LLP
By: /s/ Scott O. Luskin
SCOTT O. LUSKIN (238082)
[e-mail]
1100 Glendon Avenue, Suite 1250
Los Angeles, California 90024
Telephone: [phone]
Facsimile: [phone]

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WHITEFORD TAYLOR &
PRESTON, LLP
STEVEN E. TILLER (pro hac vice)
[e-mail]
LEONICE A. WURST (pro hac vice)
[e-mail]
Seven Saint Paul Street – Suite 1300
Baltimore, MD 21202-1626
Telephone: [phone]
Facsimile: 410-223-4325
Attorneys for Intervenor,
The Association for Childhood
Education International and
The Hill Foundation, Inc.

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UNOPPOSED MOTION REQUESTING LEAVE
FOR INTERVENERS TO BE EXCUSED FROM APPEARING

DECLARATION

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I, Scott O. Luskin, am the CM/ECF User whose identification and
password are being used to file this: UNOPPOSED MOTION
3 REQUESTING LEAVE FOR INTERVENERS TO BE EXCUSED
FROM APPEARING. In compliance with L.R. 5-4.3.4 (a)(2)(i), I hereby
4 attest that Kelly M. Klaus and Mark C. Rifkin have no objection to this motion.
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Dated: June 21, 2016

By: /s/ Scott O. Luskin
SCOTT O. LUSKIN

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4836-5061-8675.1

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UNOPPOSED MOTION REQUESTING LEAVE
FOR INTERVENERS TO BE EXCUSED FROM APPEARING