STIPULATION RE: CONTINUING DEADLINE FOR TIME WARNER INC. TO RESPOND TO PLAINTIFFS COMPLAINT

EDWARD M. CHEN, District Judge.

Pursuant to Civil Local Rule 6-1(a), Plaintiffs John Doe One, John Doe Two, John Doe Three, John Doe Four, and John Doe Five (collectively, "Plaintiffs") and Defendant Warner Media, LLC, as successor in interest to Time Warner Inc. ("Warner Media")1 hereby stipulate as follows:

WHEREAS, on February 16, 2018, Plaintiffs commenced this action against CVS Health Defendants and Amtrak, see ECF No. 1;

WHEREAS, Plaintiffs recently amended the complaint on June 14, 2018 to add Warner Media as a Defendant, and then subsequently corrected that amended complaint on June 18, 2018, see ECF No. 75;

WHEREAS, Warner Media was not served with the First Amended Class Action Complaint until June 21, 2018, making its deadline to respond to Plaintiffs' complaint due on July 12, 2018;

WHEREAS, the law firm of Robinson & Cole LLP ("R&C") was recently retained to serve as lead counsel for Warner Media and, on July 17, 2018, retained the undersigned as local counsel, who shall be filing pro hac vice applications on behalf of Attorneys Michael H. Bernstein and Jean E. Tomasco of R&C;

WHEREAS, on July 11, 2018, Patrick W. Begos of R&C contacted Plaintiffs' counsel to state that R&C had been engaged by Warner Media as counsel for Defendant, Warner Media, and requesting that Plaintiffs consent to an extension beyond Defendant's then current July 12, 2018 deadline, until August 31, 2018, to respond to the complaint;

WHEREAS, ON July 11, 2018, counsel for Plaintiffs responded to Mr. Begos, granting an extension until July 27, 2018 to be uniform with that provided to Defendant Lowe's;

WHEREAS, on July 13, 2018, Michael H. Bernstein of R&C contacted Plaintiffs' counsel to state that R&C would be associating in as lead counsel for Defendant, Warner Media, and requesting that Plaintiffs consent to an extension until August 10, 2018, to respond to the complaint;

WHEREAS, counsel for Warner Media has been only recently retained and were not previously involved in this litigation, and further given that Attorney Bernstein will be out of the country through August 2, 2018, Warner Media and its counsel require additional time to review the pleadings and the proceedings in the case thus far, and determine an appropriate response;

WHEREAS, on July 20, 2018, two of the other named Defendants filed motions to dismiss directed at the First Amended Complaint (ECF Nos. 87 and 89), and those motions have been set for hearing on September 27, 2018 at 1:30 p.m.; and

WHEREAS, extending the deadline for Warner Media to respond to the operative complaint to August 10, 2018, and if Warner Media elects to file a motion directed at the pleading would set it for September 27, 2018, the same hearing date as the other pending motions, should not alter the date of any event or any deadline already fixed by Court order.

NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties through their undersigned counsel, that (1) Warner Media shall respond to Plaintiffs' complaint on or before August 10, 2018, (2) if Warner Media elects to file a motion directed at the pleading would set it for September 27, 2018, the same hearing date as the other pending motions; (3) this Stipulation shall not affect any other deadlines presently scheduled in the case, and (4) by entering into this Stipulation, Plaintiffs do not waive any claim or defense to any response that may be submitted by Warner Media.

IT IS SO ORDERED.

ATTESTATION PURSUANT TO LOCAL RULE 5-1(i)(3)

I hereby attest that I, Scott D. Mroz, as the ECF-filer of this document, have obtained the concurrence of all other signatories to the document prior to filing.