Andersen v. Atlantic Recording Corporation et al

Filing 19

Andersen v. Atlantic Recording Corporation et al

Doc. 1

Kenneth R. Davis, II, OSB No. 97113 [e-mail] William T. Patton, OSB No. 97364 [e-mail] m LANE POWELL PC 601 SW Second Avenue, Suite 2100 Portland, Oregon 97204-3158 Telephone: [phone] Facsimile: 503.778.2200 Attorneys for Defendants Atlantic Recording Corporation, Priority Records LLC, Capitol Records, Inc., UMG Recordings, Inc., BMG Music, Recording Industry Associat ion of America, and Settlement Support Center, LLC

UNITED STATES DISTRICT COURT DISTRICT OF OREGON

TANYA ANDERSEN, Individually and as Representative of Others Similarly Situated, Plaint iff, v. ATLANTIC RECORDING CORPORATION, a Delaware corporation; PRIORITY RECORDS, LLC, a California limited liability company; CAPITOL RECORDS, INC., a Delaware corporation; UMG RECORDINGS, INC., a Delaware corporation; BMG MUSIC, a New York general partnership; RECORDING INDUSTRY ASSOCIATION OF AMERICA; SAFENET, INC., f/k/a MEDIA SENTRY, INC., a Delaware corporation; SETTLEMENT SUPPORT CENTER, LLC, a Washington limited liability company, Defendants.

CV No. 3:07-CV-934-BR Defendants' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY

PAGE 1 - UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY
LANE POWELL PC 601 SW SECOND AVENUE, SUITE 2100
PORTLAND, OREGON 97204-3158 503.778.2100 FAX: [phone]

707507.0010/661305.1

Dockets.Justia.com

CERTIFICATION Counsel for Defendants, Atlantic Recording Corp., Priority Records, LLC, Capitol Records, Inc., BMG Music, (collectively "Record Companies"), Recording Industry Associatio n of America ("RIAA"), and Settlement Support Center, LLC (hereinafter "Defendants"), certifies that they have conferred with Plaintiff's counsel regarding this request and are authorized to represent that Plaintiff does not oppose the relief sought herein. MOTION Defendants move this court for an extension of time to file a Reply in Support of Defendants' Motion to Dismiss First Amended Complaint ("Motion") until and including October 19, 2007 and in support thereof state as follows: Defendants filed their Motion on September 12, 2007. (Doc. No. 13, 14.) Pursuant to an agreed upon extension of time, Plaintiff filed her Response to Defendants' Motion (Doc. No. 17) on September 28, 2007. Per the Court's Order (Doc. No. 16), Defendants' Reply is currently due on October 12, 2007. Defendants' lead national counsel is in trial from October 2-4, 2007, in the matter of Virgin Records America, Inc. et al. v. Thomas, Case No. 06-cv-1497 in the District Court of Minnesota, and will be unavailable from October 1-5, 2007, due to trial related activities and travel. Accordingly, Defendants request, and Plaintiff does not oppose, an

extension of time until and including October 19, 2007.

PAGE 2 - UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY
LANE POWELL PC 601 SW SECOND AVENUE, SUITE 2100
PORTLAND, OREGON 97204-3158 503.778.2100 FAX: [phone]

707507.0010/661305.1

This request is not filed for the purpose of delay and no party will be prejudiced by the granting of this motion. This extension request will not impact any other settings or deadlines in this case. DATED: October 2, 2007 LANE POWELL PC

By /s/ William T. Patton Kenneth R. Davis, II, OSB No. 97113 William T. Patton, OSB No. 97364 Telephone: [phone] Attorneys for Defendants Atlantic Recording Corporation, Priority Records LLC, Capitol Records, Inc., UMG Recordings, Inc., BMG Music, Recording Industry Associat ion of America, and Settlement Support Center, LLC

PAGE 3 - UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY
LANE POWELL PC 601 SW SECOND AVENUE, SUITE 2100
PORTLAND, OREGON 97204-3158 503.778.2100 FAX: [phone]

707507.0010/661305.1