GoldieBlox, Inc. v. Island Def Jam Music Group et al

Filing 27

STIPULATION WITH PROPOSED ORDER re Extension of Time filed by GoldieBlox, Inc.. (Attachments: # 1 Declaration of Daralyn J. Durie, # 2 Proposed Order)(Durie, Daralyn) (Filed on 1/27/2014)

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1 2 3 4 5 6 DURIE TANGRI LLP DARALYN J. DURIE (SBN 169825) ddurie@durietangri.com JOSEPH C. GRATZ (SBN 240676) jgratz@durietangri.com 217 Leidesdorff Street San Francisco, CA 94111 Telephone: 415-362-6666 Facsimile: 415-236-6300 Attorneys for Plaintiff and Counter-Defendant GOLDIEBLOX, INC. 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE NORTHERN DISTRICT OF CALIFORNIA 10 SAN JOSE DIVISION 11 GOLDIEBLOX, INC., 12 13 14 Case No. 5:13-cv-05428-DMR Plaintiff, v. BROOKLYN DUST MUSIC; BEASTIE BOYS; RICK RUBIN; and ADAM HOROVITZ, DECLARATION OF DARALYN J. DURIE IN SUPPORT OF STIPULATED EXTENSION OF TIME Ctrm: 8 – 4th Floor Judge: Honorable Lucy H. Koh 15 Defendants. 16 18 MICHAEL DIAMOND; DECHEN YAUCH, EXECUTOR OF THE ESTATE OF ADAM YAUCH; BROOKLYN DUST MUSIC; BEASTIE BOYS; and ADAM HOROVITZ, 19 Counter-Claimants, 17 20 21 22 v. GOLDIEBLOX, INC., Counter-Defendant. 23 24 25 26 27 28 DECLARATION OF DARALYN J. DURIE IN SUPPORT OF STIPULATED EXTENSION OF TIME CASE NO. 5:13-CV-05428-LHK 1 I, Daralyn J. Durie, declare as follows: 2 1. I am an attorney at law licensed to practice in the state of California. I am a partner with 3 the law firm of Durie Tangri LLP, counsel for Plaintiff and Counter-Defendant GoldieBlox Inc. 4 (“GoldieBlox”) in this matter. I have personal knowledge of the following facts and, if called to testify, I 5 could and would testify competently to the matters stated herein. 6 7 2. Reason for the Extension of Time. The parties have met and conferred and jointly agree to the requested extension so the parties can continue to explore settlement options. 8 3. Prior Time Modifications. On January 9, 2014 the Court vacated all dates previously 9 set in this case upon reassignment to Judge Koh. Dkt. No. 24. On January 22, 2014, the Court issued a 10 Clerk’s Notice Setting Case Management Following Reassignment, setting a deadline of March 12, 2014 11 for the parties to submit a Case Management Statement, and setting a Case Management Conference for 12 March 19, 2014. Dkt. No. 25. Also on January 22, the Court granted the parties’ stipulated request to 13 extend by twenty-one (21) days all dates including GoldieBlox’s time to respond to the Beastie Boys’ 14 counterclaims. Dkt. No. 26. 1 15 16 4. extending the dates twenty-one (21) days. I declare under penalty of perjury under the laws of the United States that the foregoing is true 17 18 Effect of Modification. The requested extension will modify all current dates by and correct. Executed on January 27, 2014 at San Francisco, California. 19 /s/ Daralyn J. Durie DARALYN J. DURIE 20 21 22 23 24 25 26 27 28 1 That stipulation was filed on January 6. Dkt. No. 21. 1 DECLARATION OF DARALYN J. DURIE IN SUPPORT OF STIPULATED EXTENSION OF TIME CASE NO. 5:13-CV-05428-LHK 1 2 3 CERTIFICATE OF SERVICE I certify that all counsel of record is being served on January 27, 2014 with a copy of this document via the Court’s CM/ECF system. 4 /s/ Daralyn J. Durie DARALYN J. DURIE 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 DECLARATION OF DARALYN J. DURIE IN SUPPORT OF STIPULATED EXTENSION OF TIME CASE NO. 5:13-CV-05428-LHK

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