The opinion of the court was delivered by: Claudia Wilken United States District Judge
REQUEST TO CONTINUE CASE
MANAGEMENT CONFERENCE AND [PROPOSED] ORDER
Date: September 6, 2011 Time: 2:00 p.m. Court: Hon. Claudia Wilken
PLAINTIFFS DFSB Kollective Co. Ltd., in conjunction with Jungle Entertainment, 21 Woolim Entertainment, Paragon Music Corp., Nega Network, Foundation Records, Aftermoon 22 Music Entertainment Inc., Roxta Music, and Spot/Monky Global (collectively "Plaintiffs"), by and 23 through their counsel of record, hereby request as follows: 24 WHEREAS Plaintiffs filed their complaint on or about March 7, 2011; 25 WHEREAS Plaintiffs filed an Ex Parte Application seeking leave to take immediate 26 discovery in order to identify various John Doe Defendants (collectively "Defendants");
WHEREAS the Court granted Plaintiffs' Application on or about April 21, 2011; WHEREAS Plaintiffs, thereafter, served discovery on various third-party service providers in order to conclusively identify and locate Defendants;
WHEREAS Plaintiffs have identified by name two of the Defendants;
WHEREAS Plaintiffs are currently preparing their First Amended Complaint and anticipate filing imminently; and
WHEREAS Plaintiffs will have 120 days from the filing of their First Amended Complaint to serve the newly named Defendants.
NOW, THEREFORE, Plaintiffs respectfully request the Court continue the Case Management Conference for approximately one hundred twenty (120) days, or not earlier than January 3, 2012.
J. Andrew Coombs, A Professional Corp.
By: ___/s Nicole L. Drey_____________________
J. Andrew Coombs Nicole L. Drey
Attorneys for Plaintiffs DFSB Kollective Co. Ltd., in conjunction with Jungle ...