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Lenz v. Universal Music Corp.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


April 9, 2009

STEPHANIE LENZ, PLAINTIFF,
v.
UNIVERSAL MUSIC CORP., UNIVERSAL A MUSIC PUBLISHING, INC., AND UNIVERSAL MUSIC PUBLISHING DEFENDANTS.

The opinion of the court was delivered by: Judge The Hon. Richard G. Seeborg

STIPULATION AND [PROPOSED] ORDER TO SHORTEN TIME ON BRIEFING SCHEDULE REGARDING PLAINTIFF'S MOTION FOR ENTRY OF PROTECTIVE ORDER Date: N/A GROUP, Time: N/A 26 Courtroom: 4

Plaintiff Stephanie Lenz ("Plaintiff") and Defendants Universal Music Corp., Universal Music Publishing, Inc. and Universal Musical Publishing Group ("Defendants"), by and through 3 their respective counsel of record, hereby declare and stipulate as follows:

WHEREAS, contemporaneous with the filing of this Stipulation, Plaintiff is filing a Motion for Entry of a Protective Order ("Motion");

WHEREAS, Defendants have indicated that they will oppose the Motion but will stipulate to the time modifications on the briefing schedule set by the Civil Local Rules as set forth below;

WHEREAS, pursuant to Civil Local Rule 6-2(a)(1), the parties state that the time modifications set forth below are requested for the following reason:

Plaintiff has requested, and Defendants have agreed, that Plaintiff's Motion for Entry of a Protective Order can be briefed on a modified schedule. The parties have agreed to stipulate to a 13 shortened briefing schedule (as set forth below), under which briefing would be completed by Friday, April 25, 2009;

WHEREAS, pursuant to Civil Local Rule 6-2(a)(2), the parties disclose that there have been five previous stipulated time modifications in this case (August 20, 2007 [Docket No. 8], October 11, 2007 [Docket No. 19], November 16, 2007 [Docket No. 26], April 30, 2008 [Docket 18 No. 35], and August 29, 2008 [Docket No. 46]). These modifications related to the briefing 19 schedules and hearing dates for the prior Motions to Dismiss and Motion to Certify, and/or the 20 date for the Case Management Conference; and

WHEREAS, pursuant to Civil Local Rule 6-2(a)(3), the parties state that the requested time modifications herein would have no effect on the schedule for the case other than to shorten 23 the time for briefing on Plaintiff's Motion;

ACCORDINGLY, THE PARTIES STIPULATE AS FOLLOWS:

The briefing schedule for Plaintiff's Motion shall be:

[a] Motion: Thursday, April 9, 2009

[b] Opposition: Monday, April 20, 2009

The Parties respectfully request that, upon the filing of the Reply, the Court set Plaintiff's Motion for argument on the Court's first available hearing date. The Parties would be amenable to conducting argument in person or by telephone conference, as the Court prefers.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

HON. RICHARD G. SEEBORG United States Magistrate Judge

20090409

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