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, by way of stipulation, have sought by the court's order, and the court has so ordered, various extensions of the deadline for Warner/Chappell to file its responsive pleading in this matter in order to allow the parties to continue their discussions regarding Plaintiff's claims and how this action should proceed, including a potential settlement, resulting in extensions of Warner/Chappell's response deadline to August 2, 2016; September 2, 2016; October 3, 2016; and November 2, 2016;

WHEREAS, the parties desire additional time to negotiate a potential settlement of this matter and thus seek an additional thirty (30) day extension of the deadline for Warner/Chappell to file its responsive pleading up to and including December 2, 2016;

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 December 2, 2016, subject to further extensions to be agreed upon by the parties and ordered by the Court.

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 December 2, 2016, subject to further extensions to be agreed upon by the parties and ordered by the Court.

IT IS SO ORDERED.