STIPULATION AND ORDER EXTENDING TIME FOR DEFENDANT TO FILE RESPONSIVE PLEADING

TROY L. NUNLEY, District Judge.

STIPULATION TO EXTEND TIME TO RESPOND

IT IS HEREBY STIPULATED, by and between Plaintiff Ronald A. Hinson ("Plaintiff") and Defendant Warner/Chappell Music, Inc. ("Warner/Chappell") as follows:

WHEREAS, Plaintiff filed his First Amended Complaint for Damages ("FAC") on January 11, 2016;

WHEREAS, Plaintiff served a Waiver of the Service of Summons (the "Waiver") on counsel for Warner/Chappell on May 6, 2016, which counsel for Warner/Chappell executed and returned on May 13, 2016;

WHEREAS, by executing and returning the Waiver, Warner/Chappell was given until July 5, 2016 (i.e., 60 days from May 6, 2016, the date on which the Waiver was served) to file an answer or motion under Rule 12;

WHEREAS Plaintiff and Warner/Chappell thereafter engaged in discussions regarding Plaintiff's claims and how this action should proceed, and on June 30, 2016 jointly filed a Stipulation for Extension of Time for Warner/Chappell to respond to Plaintiff's FAC, thereby extending Warner/Chappell's response deadline by fifteen (15) days to July 20, 2016, subject to further extensions to be agreed upon by the parties;

WHEREAS Plaintiff and Warner/Chappell subsequently filed jointly on July 19, 2016, a Stipulation Extending Time for Defendant to File Responsive Pleading for an additional thirteen (13) days until August 2, 2016, to respond to the Complaint;

WHEREAS Plaintiff and Warner/Chappell subsequently filed jointly on or about July 28, 2016, a Stipulation Extending Time for Defendant to File Responsive Pleading for an additional thirty (30) days until September 2, 2016;

WHEREAS Plaintiff and Warner/Chappell subsequently filed jointly on August 30, 2016, a Stipulation Extending Time for Defendant to File Responsive Pleading for an additional thirty (30) days until October 3, 2016;

WHEREAS, the parties desire to extend the foregoing extension another thirty (30) days until November 2, 2016 in order to provide the parties additional time to continue their discussions regarding Plaintiff's claims and how this action should proceed;

WHEREAS Plaintiff and Warner/Chappell are the only parties affected by this stipulation, and so this stipulation will not result in prejudice to any party;

NOW THEREFORE, the parties, by and through their counsel of record, hereby stipulate and agree that Warner/Chappell should be given an additional thirty (30) days to respond to Plaintiff's FAC, so that Warner/Chappell must file an answer or motion under Rule 12 by no later than November 2, 2016, subject to further extensions to be agreed upon by the parties.

Nothing in this stipulation shall constitute a waiver of any arguments or defenses that Warner/Chappell may wish to assert in its responsive pleadings, all of which are expressly reserved.

IT IS SO STIPULATED AND AGREED.

ORDER

Based upon the foregoing Stipulation and good cause appearing, IT IS HEREBY ORDERED that Warner/Chappell may respond to the First Amended Complaint by November 2, 2016, subject to further extensions to be agreed upon by the parties and ordered by the Court.

IT IS SO ORDERED.