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)

Download PDF
1 GLENN D. POMERANTZ (State Bar No. 112503) 2 KELLY M. KLAUS (State Bar No. 161091) 3 ADAM I. KAPLAN (State Bar No. 268182) 4 MUNGER, TOLLES & OLSON LLP 355 South Grand Avenue 5 Thirty-Fifth Floor Los Angeles, California 90071-1560 6 Telephone: (213) 683-9100 Facsimile: (213) 687-3702 7 Attorneys for Defendants 8 Warner/Chappell Music, Inc. and Summy-Birchard, Inc. 9 10 11 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION 12 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, 16 Plaintiffs, 17 v. 18 WARNER/CHAPPELL MUSIC, INC., 19 and SUMMY-BIRCHARD, INC., 20 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. 21 22 23 24 25 26 27 28 -1- DECLARATION OF KELLY M. KLAUS ISO STIPULATION 1 I, Kelly M. Klaus, hereby declare: 2 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. 7 8 9 10 11 12 13 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. 16 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. 19 20 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. 22 23 24 25 /s/ Kelly M. Klaus KELLY M. KLAUS 26 27 28 -2- DECLARATION OF KELLY M. KLAUS ISO STIPULATION

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?