Sledge et al v. Warner Music Group Corp.

Filing 69

STIPULATION AND ORDER RE 68 SCHEDULING ORDER. Further Case Management Conference set for 6/27/2013 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 4/18/13. (cl, COURT STAFF) (Filed on 4/18/2013)

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MUNGER, TOLLES & OLSON LLP
GLENN POMERANTZ (SBN 112503)
TAMERLIN GODLEY (SBN 194507)
MELINDA E. LEMOINE (SBN 235670)
ANJAN CHOUDHURY (SBN 236039)
[e-mail]
[e-mail]
[e-mail]
[e-mail]
355 South Grand Avenue
Thirty-Fifth Floor
Los Angeles, CA 90071-1560
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendant
WARNER MUSIC GROUP CORP.

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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DEBRA SLEDGE, JOAN SLEDGE,
KATHY SLEDGE LIGHTFOOT and KIM
SLEDGE ALLEN, jointly d/b/a “SISTER
SLEDGE”; RONEE BLAKLEY; and
GARY WRIGHT, on behalf of themselves
and all others similarly situated,

CASE NO. 12-CV-0559-RS
JOINT STATEMENT/STIPULATION AND
[PROPOSED] SCHEDULING ORDER
Judge:

Hon. Richard Seeborg

Plaintiffs,

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v.

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WARNER MUSIC GROUP CORP.,
Defendant.

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20596539.1

JOINT STIPULATION
AND [PROPOSED] ORDER
CASE NO. 12-CV-0559-RS

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Plaintiffs in the above captioned consolidated action and Defendant Warner Music Group
Corp. (“WMG”) together submit this joint statement/stipulation.
On August 31, 2012, this Court granted a stay of the proceedings to allow the parties to

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participate in settlement discussions and set a further status conference on March 14, 2013. Over

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the course of those six months, the parties diligently participated in settlement negotiations. They

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exchanged information and analysis to facilitate the negotiations. They participated in two full

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day mediation sessions with the Honorable Daniel Weinstein (Ret.), and they held additional

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phone conferences with and without the mediator.

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On February 28, 2013, pursuant to the Court’s stay order, the parties made a joint filing

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with the Court reporting on the status of the negotiations and requesting that the case remained

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stayed because of the ongoing talks. The Court extended the stay, setting a Case Management

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Conference for May 2, 2013 and asking the parties to make a joint filing regarding the status of

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the negotiations on April 18, 2013. The Court’s order, like the first, provided that if, at the time

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of the filing of the joint statement the parties agreed that further settlement discussions would be

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fruitful, they could seek additional time for further negotiations. Stay Order at 3.

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The parties have continued to diligently pursue settlement negotiations over the last two

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months. In particular, the parties participated in an in-person settlement meeting on March 6,

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2013. Thereafter, the parties continued their discussions by phone and email, which discussions

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are ongoing. While the parties have not reached a settlement at this juncture, the negotiations are

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constructive and progress has been made. All parties are committed to continuing the settlement

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discussions at this time.

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For these reasons, the parties jointly file this statement/stipulation to inform the Court that

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they believe further settlement discussions would be fruitful and to seek additional time for

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continued negotiations. Specifically, the parties hereby agree and stipulate, subject to the

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approval of the Court, to the following:

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1. A further Case Management Conference to be set in 60 days, subject to the

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schedule of the Court; and shall be scheduled for 6/27/13 at 10:00 a.m.

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2. Fourteen days before the Case Management Conference—or before that date if
20596539.1

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JOINT STIPULATION
AND [PROPOSED] ORDER
CASE NO. 12-CV-0559-RS

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Plaintiffs and/or WMG believe that settlement cannot be reached—the parties shall

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file a joint statement/stipulation with the Court alerting the Court to the fact that

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settlement could not be reached and resetting a schedule for WMG’s response to

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the Amended Complaint (which deadline for WMG’s response shall be no sooner

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than 30 days from the date of the joint statement) and subsequent dates and

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deadlines. In the alternative, if the parties agree that further settlement discussions

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would be fruitful, the parties can instead file a joint statement/stipulation seeking

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additional time for further settlement negotiations.

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Dated: April 18, 2013

Respectfully Submitted,

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By:

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/s/ Tamerlin J. Godley
Tamerlin J. Godley
MUNGER, TOLLES & OLSON LLP

Attorneys for Defendant
Warner Music Group Corp.

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Dated: April 18, 2013

Respectfully Submitted,

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By:

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/s/ Daniel L. Warshaw
Daniel L. Warshaw
PEARSON, SIMON & WARSHAW, LLP

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Interim Lead Counsel Representative for Plaintiffs*

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* A complete list of the attorneys for Plaintiffs is attached to the Amended Complaint.

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20596539.1

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JOINT STIPULATION
AND [PROPOSED] ORDER
CASE NO. 12-CV-0559-RS

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Filer’s Attestation

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I, Tamerlin J. Godley, am the ECF user whose identification and password are being used

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to file this JOINT STATEMENT/STIPULATION AND [PROPOSED] SCHEDULING ORDER.

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I hereby attest that the counsel listed above concur in this filing.

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Dated: April 18, 2013
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/s/ Tamerlin J. Godley
Tamerlin J. Godley

______

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20596539.1

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JOINT STIPULATION
AND [PROPOSED] ORDER
CASE NO. 12-CV-0559-RS

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PURSUANT TO THIS STIPULATION, IT IS SO ORDERED.

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4/18/13
Dated: ___________________

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_________________________________
Honorable Richard Seeborg
U.S. District Judge

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20596539.1

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JOINT STIPULATION
AND [PROPOSED] ORDER
CASE NO. 12-CV-0559-RS