Rupa Marya v. Warner Chappell Music Inc

Filing 77

STIPULATION for Extension of Time to File Answer to December 11, 2013 re Amended Complaint, 75 filed by Defendants Summy-Birchard Inc, Warner Chappell Music Inc. (Attachments: # 1 Declaration Kelly M. Klaus iso Stipulation, # 2 Proposed Order)(Klaus, Kelly)

1 GLENN D. POMERANTZ (State Bar No. 112503)
[e-mail]
2 KELLY M. KLAUS (State Bar No. 161091)
[e-mail]
3 ADAM I. KAPLAN (State Bar No. 268182)
[e-mail]
4 MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue
5 Thirty-Fifth Floor
Los Angeles, California 90071-1560
6 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Defendants
8 Warner/Chappell Music, Inc. and
Summy-Birchard, Inc.
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION

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13 GOOD MORNING TO YOU
PRODUCTIONS CORP.; ROBERT
14 SIEGEL; RUPA MARYA; and
MAJAR PRODUCTIONS, LLC; On
15 Behalf of Themselves and All Others
Similarly Situated,
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Plaintiffs,
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v.
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WARNER/CHAPPELL MUSIC, INC.,
19 and SUMMY-BIRCHARD, INC.,
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Lead Case No. CV 13-04460-GHK
(MRWx)
DECLARATION OF KELLY M.
KLAUS IN SUPPORT OF
STIPULATION REGARDING
DEADLINE FOR DEFENDANTS’
RESPONSE TO PLAINTIFFS’
THIRD AMENDED
CONSOLIDATED COMPLAINT

Defendants.

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DECLARATION OF
KELLY M. KLAUS ISO STIPULATION

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I, Kelly M. Klaus, hereby declare:

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1.

I am an attorney duly licensed to practice law in the state of California

3 and am a partner at the law firm of Munger, Tolles & Olson LLP, counsel for
4 Defendants Warner/Chappell Music, Inc. and Summy-Birchard, Inc. I have
5 personal knowledge of the facts stated herein and if called upon to testify as to them,
6 I could and would competently do so.
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2.

Defendants have informed Plaintiffs that (1) Defendants presently

intend to answer the Third Amended Consolidated Complaint, (2) Defendants
request a brief extension, by two-weeks, of their deadline for responding to the
Third Amended Consolidated Complaint, given the number of allegations in the
Third Amended Consolidated Complaint and the fact that the current deadline is the
day before Thanksgiving, and (3) if Defendants ultimately do file a motion, they
will meet-and-confer in advance of the motion as required by the Local Rules, and
will stipulate to a request to adjust the briefing schedule on any such motion to

14 accommodate the schedules of Plaintiffs’ counsel during the December holiday
15 season.
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3.

The parties have met and conferred, and Plaintiffs have agreed to

17 stipulate to a two-week extension of Defendants’ response deadline pursuant to the
18 terms of the preceding paragraph.
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I declare under penalty of perjury that the foregoing is true and correct.

21 Executed this 19th day of November, 2013, in San Francisco, California.
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/s/ Kelly M. Klaus
KELLY M. KLAUS

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DECLARATION OF
KELLY M. KLAUS ISO STIPULATION