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

Filing 29

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 2/14/2014)

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DURIE TANGRI LLP
DARALYN J. DURIE (SBN 169825)
[e-mail]
JOSEPH C. GRATZ (SBN 240676)
[e-mail]
217 Leidesdorff Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415-236-6300
Attorneys for Plaintiff and Counter-Defendant
GOLDIEBLOX, INC.

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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GOLDIEBLOX, INC.,

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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

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Defendants.
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MICHAEL DIAMOND; DECHEN YAUCH,
EXECUTOR OF THE ESTATE OF ADAM
YAUCH; BROOKLYN DUST MUSIC;
BEASTIE BOYS; and ADAM HOROVITZ,

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Counter-Claimants,

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v.
GOLDIEBLOX, INC.,
Counter-Defendant.

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DECLARATION OF DARALYN J. DURIE IN SUPPORT OF STIPULATED EXTENSION OF TIME
CASE NO. 5:13-CV-05428-LHK

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I, Daralyn J. Durie, declare as follows:

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1.

I am an attorney at law licensed to practice in the state of California. I am a partner with

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the law firm of Durie Tangri LLP, counsel for Plaintiff and Counter-Defendant GoldieBlox Inc.

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(“GoldieBlox”) in this matter. I have personal knowledge of the following facts and, if called to testify, I

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could and would testify competently to the matters stated herein.

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2.

Reason for the Extension of Time. The parties have met and conferred and jointly agree

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to the requested extension so the parties can continue to explore settlement options. The parties have

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made substantial progress toward settlement.

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3.

Prior Time Modifications. On January 9, 2014 the Court vacated all dates previously

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set in this case upon reassignment to Judge Koh. Dkt. No. 24. On January 22, 2014, the Court issued a

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Clerk’s Notice Setting Case Management Following Reassignment, setting a deadline of March 12, 2014

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for the parties to submit a Case Management Statement, and setting a Case Management Conference for

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March 19, 2014. Dkt. No. 25. Also on January 22, the Court granted the parties’ stipulated request to

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extend by twenty-one (21) days all dates including GoldieBlox’s time to respond to the Beastie Boys’

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counterclaims. Dkt. No. 26. On January 28, 2014, the Court granted the parties’ second stipulated

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request to extend by twenty-one (21) days all dates including GoldieBlox’s time to respond to the Beastie

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Boys’ counterclaims. Dkt. No. 28.

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4.

Effect of Modification. The requested extension will modify all current dates by

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
and correct. Executed on February 14, 2014 at San Francisco, California.

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/s/ Daralyn J. Durie
DARALYN J. DURIE

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DECLARATION OF DARALYN J. DURIE IN SUPPORT OF STIPULATED EXTENSION OF TIME
CASE NO. 5:13-CV-05428-LHK

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CERTIFICATE OF SERVICE

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I certify that all counsel of record is being served on February 14, 2014 with a copy of this

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document via the Court’s CM/ECF system.

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/s/ Daralyn J. Durie
DARALYN J. DURIE

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DECLARATION OF DARALYN J. DURIE IN SUPPORT OF STIPULATED EXTENSION OF TIME
CASE NO. 5:13-CV-05428-LHK