UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
December 16, 2011
ROB ZOMBIE, A/K/A ROBERT WOLFGANG ZOMBIE, F/K/A ROBERT CUMMINGS;
WHITE ZOMBIE, A GENERAL PARTNERSHIP;
WHITESNAKE, A DOING BUSINESS DESIGNATION OF DAVID COVERDALE, BY AND
FOR WHITESNAKE PRODUCTIONS (OVERSEAS) LIMITED; AND
DAVE MASON, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
UMG RECORDINGS, INC., A DELAWARE CORPORATION, DEFENDANT.
The opinion of the court was delivered by: The Honorable Susan Illston United States District Judge
PHILLIPS, ERLEWINE & GIVEN LLP DAVID M. GIVEN (firstname.lastname@example.org) 2 NICHOLAS A. CARLIN (email@example.com) ALEXANDER H. TUZIN (firstname.lastname@example.org) 3 50 California Street, 35th Floor San Francisco, California 94111 4 Telephone: 415/398-0900 Facsimile: 415/398-0911 5 LAW OFFICES OF LEONARD B. SIMON P.C. 6 LEONARD B. SIMON (email@example.com) 655 West Broadway, Suite 1900 7 San Diego, California 92101 Telephone: 619/338-4549 8 Facsimile: 619/231-7423 9 [ADDITIONAL COUNSEL ON SIGNATURE PAGE] 10 Attorneys for Plaintiffs and the Putative Class 11 12
STIPULATION TO CONSOLIDATE CASE WITH CASE NO. CV11-01613 SI
This stipulation is based on the following facts: 2
1. On June 1, 2011, this Court entered an order granting plaintiffs' administrative 3 motion to relate this case with lead case James v. UMG Recordings, Inc., Case No. CV11-01613 SI 4 (the "James" action) (Doc. No. 19). 5
2. Plaintiffs have requested that defendant agree to consolidate the James action with 6 this action. Defendant is agreeable to such consolidation solely for administrative convenience and 7 for no other reason, and on that basis is willing to stipulation to consolidation, on the terms set out 8 herein. 9
3. The parties hereby agree and stipulate that this action may be consolidated for all 10 purposes with the James action pursuant to Fed. R. Civ. P. 42(a)(2). 11
4. The parties agree and stipulate as a material condition of this stipulation that 12 consolidation of these two actions shall not be used or considered in any manner, directly or 13 indirectly, for any purpose unrelated to consolidation, including but not limited to in connection with 14 any motion concerning class certification. The parties further agree that this stipulation is without 15 prejudice to Defendant's right to move to sever the actions at such time as Defendant deems such a 16 motion advisable, and plaintiffs reserve the right to oppose that motion.
IT IS SO STIPULATED.
Pursuant to stipulation, IT IS SO ORDERED.
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