IN RE: WARNER MUSIC GROUP CORP. DIGITAL DOWNLOADS LITIGATION
Bruce L. Simon, (Bar No. 96241), Daniel L. Warshaw, PEARSON, SIMON & WARSHAW, LLP, San Francisco, California, Attorneys for Plaintiffs and the Class.
Tamerlin J. Godley, MUNGER, TOLLES & OLSON LLP, Attorneys for Defendant Warner Music Group Corp.
LOCAL RULE 6-2 JOINT STIPULATION TO SHORTEN TIME FOR HEARING MOTION FOR PRELIMINARY APPROVAL OF CLASS SETTLEMENT
RICHARD SEEBORG, District Judge.
Pursuant to Local Rule 6-2, Plaintiffs Kathy Sledge Lightfoot, Gary Wright and Ronee Blakley in the above captioned consolidated action and Defendant Warner Music Group Corp. ("WMG") (collectively referred to as "the Parties") together submit the following joint stipulation in regard to the following facts:
WHEREAS, the Parties have been negotiating a settlement of this putative class action for many months;
WHEREAS, the details of the settlement of any class action are detailed and take extensive negotiations, particularly where, as here, the settlement contemplated involves both payment for past relief and increased royalty rates in the future;
WHEREAS, the Parties have now agreed to a proposed settlement of the matter, subject to the approval of the Court, and Plaintiffs have concurrently filed with this stipulation a Notice of Motion and Motion For Preliminary Approval of Class Action Settlement (the "Motion");
WHEREAS, the currently scheduled hearing date for the Motion is February 6, 2014;
WHEREAS, the Parties agreed to provide notice to potential class members of the settlement, if it is preliminarily approved, with their individually mailed royalty statements;
WHEREAS, the next mailing of WMG's royalty statements is for the period ending December 31, 2013, which mailing should begin on or around February 15, 2014;
WHEREAS, the Parties endeavored to complete their negotiations in time to allow 35 days between the filing of the Motion and the hearing on the Motion as required by the Local Rules and still allow for notice to be mailed with the potential class members' upcoming royalty statements;
WHEREAS, because of the many issues that needed to be negotiated and agreed upon the Parties were unable to meet the 35-day deadline and still provide for notice to potential class members in the upcoming royalty statements;
WHEREAS, to address this issue, the Parties have agreed, subject to the Court's approval, to shorten the time from the filing of the Motion to the hearing on the Motion so ...