Andersen v. Atlantic Recording Corporation et al

Filing 8

Andersen v. Atlantic Recording Corporation et al

D

Doc.

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, and Recording Industry Associat ion of America

UNITED STATES DISTRICT COURT DISTRICT OF OREGON

TANYA ANDERSEN, 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

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

707507.0010/653758.1

ockets.Justia.com

CERTIFICATION Counsel for Defendants, Atlantic Recording Corp., Priority Records, LLC, Capitol Records, Inc., UMG Recordings, Inc., BMG Music, (collectively "Record Companies"), and Recording Industry Associat ion of America ("RIAA"), (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 order extending the deadline for their response to Plaintiff's First Amended Complaint until and including September 12, 2007. Plaint iff's initial Complaint was filed on June 22, 2007. Counsel for Defendants

accepted service on August 7, 2007, thereby making Defendants' responsive pleading due on or before August 27, 2007. However on August 15, 2007 Plaintiff filed a First Amended

Complaint. By way of agreement on August 23, 2007 counsel for the Recording Companies and the RIAA agreed to accept service of the Amended Complaint on behalf of those defendants only, while counsel for Plaintiff agreed to an additional twenty days for Defendants to answer or otherwise respond. Accordingly, Defendants request until and including September 12, 2007 to respond to Plaintiff's First Amended Complaint.

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

707507.0010/653758.1

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: August 27, 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, and Recording Industry Association of America

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

707507.0010/653758.1

CERTIFICATE OF SERVICE The undersigned hereby certifies that a true copy of the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME was served upon counsel for the Plaintiff, with firstclass postage fully paid, and by depositing said envelope in a United States Post Office depository on the 27th day of August 2007. Lory R. Lybeck, Esq. Benjamin R. Justus, Esq. Lybeck Murphy, LLP 7525 SE 24th Street, Suite 500 Mercer Island, WA 98040 Richard A. Adams, Esq. James C. Wyly, Esq. Patton, Roberts, McWilliams & Capshaw, LLP Century Bank Plaza, Suite 400 2900 St. Michael Drive Texarkana, TX 75503

/s/ William T. Patton William T. Patton

PAGE 1 - CERTIFICATE OF SERVICE
LANE POWELL PC 601 SW SECOND AVENUE, SUITE 2100
PORTLAND, OREGON 97204-3158 503.778.2100 FAX: [phone]

707507.0010/653758.1