Bryan Pringle v. William Adams Jr et al

Filing 153

STIPULATION for Order modifying the dates for initial and rebuttal expert disclosures and the deadline for completion of expert discovery filed by plaintiff Bryan Pringle. (Attachments: # 1 Proposed Order)(Holley, Colin)

1 Dean A. Dickie (appearing Pro Hac Vice)
[e-mail]
2 Kathleen E. Koppenhoefer (appearing Pro Hac Vice)
[e-mail]
3 MILLER, CANFIELD, PADDOCK AND STONE, P.L.C.
225 West Washington Street, Suite 2600
4 Chicago, IL 60606
Telephone: [phone]
5 Facsimile: 312.460.4288

LLP

HAMPTONHOLLEY

2101 East Coast Highway, Suite 260
Corona del Mar, California 92625

6 Ira Gould (appearing Pro Hac Vice)
[e-mail]
7 Ryan L. Greely (appearing Pro Hac Vice)
[e-mail]
8 GOULD LAW GROUP
120 North LaSalle Street, Suite 2750
9 Chicago, IL 60602
Telephone: [phone]
10 Facsimile: 312.726.1328
11 George L. Hampton IV (State Bar No. 144433)
[e-mail]
12 Colin C. Holley (State Bar No. 191999)
[e-mail]
13 HAMPTONHOLLEY LLP
2101 East Coast Highway, Suite 260
14 Corona del Mar, California 92625
Telephone: [phone]
15 Facsimile: 949.718.4580
16 Attorneys for Plaintiff
BRYAN PRINGLE
17
18

UNITED STATES DISTRICT COURT

19

CENTRAL DISTRICT OF CALIFORNIA

20

SOUTHERN DIVISION
)
)
)
Plaintiff,
)
)
v.
)
)
WILLIAM ADAMS, JR.; STACY
)
FERGUSON; ALLAN PINEDA; and
)
JAIME GOMEZ, all individually and
collectively as the music group The Black )
)
Eyed Peas, et al.,
)
)
Defendants.
)

21 BRYAN PRINGLE, an individual,

Case No. SACV 10-1656 JST(RZx)

22

STIPULATION REQUESTING
COURT TO CONTINUE EXPERT
DISCOVERY CUTOFF DATES

23
24
25
26
27
28

4842-5913-6008 - v. 1

1

This Stipulation is made by and among Plaintiff Bryan Pringle (“Plaintiff”)

2 and Defendants, William Adams, Stacy Ferguson, Allan Pineda, Jaime Gomez,
3 individually and collectively p/k/a The Black Eyed Peas, Tab Magnetic Publishing,
4 Headphone Junkie Publishing, LLC, will.i.am. music, llc, Jeepney Music, Inc.,
5 Cherry River Music Co., EMI April Music, Inc., UMG Recordings, Inc., Interscope
6 Records, Shapiro, Bernstein & Co., Inc., Frederic Riesterer, and David Guetta
7 (jointly “Defendants”) (Plaintiffs and Defendants are hereafter collectively referred
8 to as the “parties”), and is made with reference to the following facts:
9

1. WHEREAS, pursuant to Rule 26(a)(2)(D), the date by which expert

10 disclosures must be made is currently November 30, 2011, and the date by which
11 rebuttal expert disclosures must be made is currently December 30, 2011.
12

2. WHEREAS, pursuant to this Court’s February 24, 2011 Scheduling Order,

13 all fact and expert discovery must be completed by November 14, 2011.
14

3. WHEREAS, the parties have agreed, subject to this Court’s approval, to

15 shorten the time by which initial expert disclosures must be made to November 23,
16 2011, and to shorten the time by which rebuttal expert disclosures must be made –
17 including Defendants’ report(s), if any, on costs and net profits attributable to the
18 alleged infringement (including but not limited to, the apportionment of such profits),
19 to December 16, 2011.
20

4. WHEREAS, the parties have further agreed, subject to this Court’s

21 approval, to extend the date by which expert discovery must be completed to January
22 6, 2012.
23

5. WHEREAS, with the exception of the deadlines by which the parties must

24 make their initial and rebuttal expert disclosures, and the deadline by which expert
25 discovery must be completed, no other deadlines, including but not limited to the
26 trial date, will be affected by this Stipulation.
27
28

BASED UPON THE FOREGOING FACTS, IT IS HEREBY STIPULATED

1

2 by and between the parties, through their respective counsel, subject to the Court’s
3 approval, that:
(a)

Initial Expert Disclosures must be made on or before November 23,

(b)

4

Rebuttal Expert Disclosures – including Defendants’ rebuttal

5 2011;
6

7 disclosures, if any, on costs and net profits attributable to the alleged infringement
8 (including but not limited to, the apportionment of such profits) must be made on or
9 before December 16, 2011; and
10

(c)

The deadline by which to complete expert discovery shall be continued

11 from November 14, 2011 to January 6, 2012.
12
13 Dated: October 25, 2011
14
15

Dean A. Dickie (appearing Pro Hac Vice)
Kathleen E. Koppenhoefer (appearing Pro Hac
Vice)
MILLER, CANFIELD, PADDOCK AND STONE,
P.L.C.
Ira Gould (appearing Pro Hac Vice)
Ryan L. Greely (appearing Pro Hac Vice)
GOULD LAW GROUP

16
17

George L. Hampton IV (State Bar No. 144433)
Colin C. Holley (State Bar No. 191999)
HAMPTONHOLLEY LLP

18
19
20

By: /s/ Dean Dickie
Attorneys for Plaintiff BRYAN PRINGLE

21
22
23
24
25

Dated: October 25, 2011

Linda M. Burrow
Alison Mackenzie
CALDWELL LESLIE & PROCTOR, PC

26
27
28

By: /s/ Linda Burrow
Attorneys for Defendants UMG RECORDINGS,
INC., and INTERSCOPE RECORDS

1

Dated: October 25, 2011

2
3
4
5
6

Donald Miller
Barry Slotnick
Tal Dickstein
LOEB & LOEB LLP
By: /s/ Donald Miller
Attorneys for Defendants DAVID GUETTA,
FREDERIC RIESTERER and
SHAPIRO,BERNSTEIN AND CO., INC.

7
8 Dated: October 25, 2011

10

Kara E. F. Cenar
Jonathan Pink
Justin Righettini
Mariangela Seale
BRYAN CAVE LLP

11

By:

9

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

/s/ Kara Cenar

Attorneys for Defendants WILLIAM ADAMS;
ALLAN PINEDA; JAIME GOMEZ, and STACY
FERGUSON p/k/a FERGIE all individually and
collectively as the music group THE BLACK
EYED PEAS; will.i.am music, llc; TAB
MAGNETIC PUBLISHING; HEADPHONE
JUNKIE PUBLISHING, LLC, CHERRY RIVER
MUSIC CO.; JEEPNEY MUSIC, INC., EMI
APRIL MUSIC

1
2
3
4
5

CERTIFICATE OF SERVICE
On October 25, 2011, I electronically filed the foregoing STIPULATION
REQUESTING COURT TO CONTINUE EXPERT DISCOVERY CUTOFF
DATES using the CM/ECF system which will send notification of such filing to the
following registered CM/ECF Users:

Barry I. Slotnick
[e-mail]
6 Donald A. Miller
[e-mail], [e-mail]
[e-mail]
7 Ira P. Gould
Tal Efriam Dickstein
[e-mail]
8
Linda M. Burrow
[e-mail], [e-mail],
[e-mail], [e-mail]
9
Ryan Christopher Williams [e-mail]
10
Kara E. F. Cenar
[e-mail]
[e-mail]
11 Ryan L. Greely
Robert C. Levels
[e-mail]
12
Kathleen E. Koppenhoefer [e-mail]
13 Rachel Aleeza Rappaport [e-mail]
Jonathan S. Pink [e-mail], [e-mail]
14
Dean A. Dickie
[e-mail], [e-mail],
15
[e-mail], [e-mail],
[e-mail], [e-mail]
16
Edwin F. McPherson
[e-mail],
17
[e-mail]
Joseph G. Vernon
[e-mail]
18
Justin Michael Righettini [e-mail]
19 Tracy B. Rane
[e-mail]
20
21
22
23
24

I am unaware of any attorneys of record in this action who are not registered
for the CM/ECF system or who did not consent to electronic service.
I certify under penalty of perjury under the laws of the United States of
America that the foregoing statements are true and correct.
Dated: October 25, 2011

/s/Colin C. Holley

25
26
27
28

George L. Hampton IV (State Bar No. 144433)
Colin C. Holley (State Bar No. 191999)
HAMPTONHOLLEY LLP
2101 East Coast Highway, Suite 260
Corona del Mar, California 92625
Telephone: [phone]
Facsimile: 949.718.4580