Free Motion for Extension of Time - District Court of Delaware - Delaware

Case 1:04-cv-00969-KAJ Document 33 Filed 07/27/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SONY MUSIC ENTERTAINMENT INC., )
a Delaware corporation; WARNER BROS. ) CIVIL ACTION No. 1:04-cv—00969—KAJ
RECORDS INC., a Delaware corporation; )
UMG RECORDINGS, INC., a Delaware )
corporation; ARISTA RECORDS LLC, a )
Delaware limited liability company; and )
ATLANTlC RECORDING )
CORPORATION, a Delaware corporation, )
)
)
Plaintiffs, )
)
vs. )
)
DEENA HALL, )
)
)
Defendant. )
)
CONSENT MOTION FOR EXTENSION OF DEADLKNES
Plaintiffs move this Court for a sixty—day extension of all deadlines inthe
above-referenced matter, including but not limited to the discovery deadline, up to
and including September 25, 2006 and the dispositive inotion deadline, up to and
including September 26, 2006. This Court may inodify its scheduling order upon
good cause shown. See P ed. R. Civ. P. l6(b). Plaintiffs assert that the following
circumstances demonstrate good cause for the above deadlines to be extended as
requested:
l. The parties are currently engaged in active settlement negotiations and
believe that a settlement will soon be reached in this case.
l

Case 1:04-cv-00969-KAJ Document 33 Filed 07/27/2006 Page 2 of 3
2. In hopes that this case will be resolved and in order to prevent
additional, unnecessary expense, Defendant has not responded to discovery served
on her on May 3 l , 2006.
3. The parties have agreed that if a settlement is not reached by August
1, Defendant will respond to Plaintii`fs’ discovery requests as soon as possible
thereafter. At that tinie, the parties will need to schedule and take depositions.
4. Despite the parties’ good-faith efforts to complete these unfinished
discovery matters before the current discovery deadline expires, Plaintiffs will not
be able to complete the discovery they need to prepare their case by July 3 i, 2006.
5. Plaintiffs have contacted Defendant by telephone regarding the
extension of the above-referenced deadlines. ln Plaintiffs’ telephone conversation
with him, Defendant expressly informed Plaintiffs that he consents to the extension
of the deadlines.
6. The requested extension will not prejudice any party and will not
cause a delay in the trial of this case, set for February 2007.
For the foregoing reasons, and upon good cause shown, Plaintiffs request
that this Court extend the deadlines as listed above.
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Case 1:04-cv-00969-KAJ Document 33 Filed 07/27/2006 Page 3 of 3
DATED: I SQQOI
Robert S. Goldman (DE Bar Not 2508)
Lisa C. MCL&llgl1II11 (DE I3a1‘No. 3113)
PHILLIPS, GOLDMAN & SPENCE, PIA.
1200 North Broom Street
Wilmington, Delaware I9806
Telephone: 302-—655—4200
Attomeys for Plaintiffs
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