Sledge et al v. Warner Music Group Corp.
Filing
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JOINT STIPULATION AND ORDER RE 59 SCHEDULING ORDER AS MODIFIED BY THE COURT. Further Case Management Conference set for 3/14/2013 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 8/31/12. (cl, COURT STAFF) (Filed on 8/31/2012)
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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)
Glenn.Pomerantz@mto.com
Tamerlin.Godley@mto.com
Melinda.LeMoine@mto.com
Anjan.Choudhury@mto.com
355 South Grand Avenue
Thirty-Fifth Floor
Los Angeles, CA 90071-1560
Telephone:
(213) 683-9100
Facsimile:
(213) 687-3702
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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 STIPULATION AND [PROPOSED]
SCHEDULING ORDER
AS MODIFIED BY THE COURT
Judge:
Hon. Richard Seeborg
Plaintiffs,
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v.
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WARNER MUSIC GROUP CORP.,
Defendant.
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18476266.1
JOINT STIPULATION & [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 the following joint stipulation in regard to the following facts:
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WHEREAS, on August 21, 2012, Plaintiffs filed a Consolidated Amended Complaint (the
“Amended Complaint”);
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WHEREAS, WMG’s response to the Amended Complaint is currently due September 28,
2012;
WHEREAS, the parties are all desirous of participating in meaningful settlement
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discussions before any of the parties expend significant attorneys’ fees in motion practice and
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discovery;
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WHEREAS, in light of this joint goal, the parties have met and conferred and agreed that
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it is in the best interest of the parties and the Court to stay all current deadlines and dates in the
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litigation for a set period of time sufficient to allow the parties to participate in such settlement
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negotiations;
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WHEREAS, the parties anticipate that there will likely need to be certain communications
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prior to any formal mediation session and that settlement could take multiple mediation sessions
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to reach agreement if any agreement can be reached;
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WHEREAS, the parties also anticipate that it may take some time to schedule a mediation
session with a mediator given the current schedules of possible mediators; and
WHEREAS, for these reasons, the parties anticipate that this process may take upward of
six months.
Accordingly, the parties hereby agree and stipulate, subject to the approval of the Court, to
the following:
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A Further Case Management Conference will be set for March 14, 2013 at 10:00 a.m.
1. All dates and deadlines currently on calendar are taken off calendar;
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2. The parties shall have until February 28, 2013 to participate in meaningful
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mediation of this dispute; and
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3. On February 28, 2013—or before that date if Plaintiffs and/or WMG believe that
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settlement cannot be reached at this juncture—a party or the parties shall file a
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statement/stipulation with the Court alerting the Court to the fact that settlement
18476266.1
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JOINT STIPULATION & [PROPOSED]
ORDER
CASE NO. 12-CV-0559-RS
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could not be reached and recommending a schedule for WMG’s response to the
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Amended Complaint (which deadline for WMG’s response shall be no sooner than
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30 days from the date of the statement) and subsequent dates and deadlines. In the
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alternative, if the parties agree that further settlement discussions would be fruitful,
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the parties can instead file a joint statement/stipulation seeking additional time for
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further settlement negotiations.
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Dated: August 31, 2012
Respectfully Submitted,
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/s/ Tamerlin J. Godley
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Tamerlin J. Godley
MUNGER, TOLLES & OLSON LLP
Attorneys for Defendant Warner Music Group
Corp.
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Dated: August 31, 2012
Respectfully Submitted,
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/s/ Daniel L. Warshaw
Daniel L. Warshaw
PEARSON, SIMON, WARSHAW & PENNY 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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Filer’s Attestation
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I, Tamerlin J. Godley, am the ECF user whose identification and password are
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being used to file this STIPULATION AND [PROPOSED] SCHEDULING ORDER. In
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compliance with General Order 45.X.B., I hereby attest that the counsel listed above concur in
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this filing.
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/s/ Tamerlin J. Godley
Tamerlin J. Godley
Dated: August 31, 2012
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JOINT STIPULATION & [PROPOSED]
ORDER
CASE NO. 12-CV-0559-RS
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PURSUANT TO THIS STIPULATION, IT IS SO ORDERED.
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8/31/12
Dated: ___________________
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_________________________________
Honorable Ricahrd Seeborg
U.S. District Judge
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JOINT STIPULATION & [PROPOSED]
ORDER
CASE NO. 12-CV-0559-RS
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