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1 | KATTEN MUCHIN ROSENMAN LLP ZIA F. MODABBER (SBN 137388) 2 || zia.modabber@kattenlaw.com ANDREW J. DEMKO (SBN 247320) andrew.demko@kattenlaw.com |] 2029 Century Park East, Suite 2600 Los Angeles, CA 90067-3012 Telephone: 310.788.4400 Facsimile: 310.788.4471 3 4 5 6 | KINSELLA WEITZMAN ISER KUMP & ALDISERT LLP 7 | HOWARD WEITZMAN (SBN 38723) 8g 9 0 hweitzman@kwikalaw.com enc ISAAC (SBN 205659) smacit ‘wikalaw.com. 808 Wilshire Boulevard, 3"° Floor Santa Monica, California 90401 Telephone: 310.566.9800 310.566.9850 Facsimil Attomeys for Defendants John Branca, as 12 || Co-Executor of the Estate of Michael J. Jackson, Sony Music Entertainment and 13 || MJJ Productions, Inc. 14 || [Additional counsel listed herein] 16 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR 17 THE COUNTY OF LOS ANGELES 18 | VERA SEROVA, an individual, on behalf of | Case No. BC 548468 herself and all others similarly situated, 19 STIPULATION AND [PROPOSED] ORDER Plaintiff, REGARDING DEFENDANTS’ PROPOSED 20 7 ANTI-SLAPP MOTION 21 | sony MUSIC ENTERTAINMENT, a Case Assigned for All Purposes to 2 | Delaware general partnership; JOHN Judge Jane L. Johnson BRANCA, as Co-Executor of the Estate of 33 | Michael J. Jackson; EDWARD JOSEPH CASCIO, an individual; JAMES VICTOR 24 | PORTE, an individual; M3} | PRODUCTIONS, INC., a California 5 | Conporation; ANGELIKSON PRODUCTIONS LLC, a New York Jersey 26 | Limited Liability Company; and DOES 1 through 50, inclusive, 27 Defendants. STIPULATION Plaintiff Vera Serova (“Plaintiff”), on the one hand, and defendants Sony Music Entertainment, John Branca, as co-executor of the Estate of Michael Jackson, MJJ Productions, aw ne | MII Productions, Inc. Edward Cascio, James Porte, and Angelikson Productions, Inc. (collectively, “Defendants”), on the other hand (collectively, the “Parties”), by and through their counsel of record, hereby stipulate and agree that: (1) the stay in this matter is lifted, (2) Defendants shall file their proposed Anti-SLAPP motion by January 20, 2016, (3) the Parties shall submit a joint statement regarding whether discovery is necessary to oppose the motion by Cer anw February 1, 2016, (4) the Court will hold a telephonic hearing on February 3, 2016 at 1:45 p.m. 10 | to address discovery, a briefing schedule, and a hearing date for the Anti-SLAPP motion, and (5) 11 | Defendants waive their right to a hearing on their Anti-SLAPP Motion within 30 days of filing 12 | the Motion. Good cause exists for the foregoing as follows: 13 WHEREAS, this case was filed on June 12, 2014; 4 WHEREAS, pursuant to this Court’s standing order, the case was stayed pending the 15 | initial case management conference; 16 WHEREAS, in their initial case management conference statement, Defendants indicated 17 | that they intended to file a special motion to strike under California's Anti-SLAPP statute; 18 WHEREAS, the Court stayed the matter for the Parties to engage in early efforts to 19 || resolve the matter. The Parties engaged in significant efforts to settle, but ultimately no 20 | agreement could be reached; 21 WHEREAS, the Court held a status conference on November 25, 2015, during which it 22 | seta filing deadline of January 20, 2016 for Defendants’ Anti-SLAPP motion; 23 WHEREAS, at the November 25, 2015 status conference, Plaintiff indicated she would 24 | make a motion to take discovery to oppose Defendants’ Anti-SLAPP motion; 25 WHEREAS, the Court ordered Plaintiff to review Defendants’ Anti-SLAPP motion once 26 | filed to determine whether, in her view, discovery was necessary to oppose the motion; 27 28 ‘STIPULATION REGARDING HEARING ON ANTI- ‘SLAPP MOTION WHEREAS, the Court set a February 3, 2016 telephone hearing to determine the need and scope of discovery necessary to oppose the Anti-SLAPP motion, if any; WHEREAS, resolving the issue of the need for discovery relating to the Anti-SLAPP motion will require a briefing schedule and hearing date that will result in a hearing more than 30 days from the filing of the Anti-SLAPP motion, and Defendants agree to waive their right to a | hearing within 30 days of such filing under Code of Civil Procedure § 425.16(f) (See Greka Integrated, Inc. v. Lowrey, 133 Cal. App. 4th 1572, 1578 (2005) (failure to object constitutes a waiver); NOW, THEREFORE, IT IS HEREBY STIPULATED by the Parties as follows: 1, The stay in this matter is lifted; 2. Defendants shall file their proposed Anti-SLAPP motion by January 20, 2016; 3. The Parties shall submit a joint statement regarding whether discovery is necessary to oppose the motion by February 1, 2016; 4, The Court will hold a telephonic hearing on February 3, 2016 at 1:45 p.m. to address discovery, a briefing schedule, and a hearing date for the Anti-SLAPP motion; and 5. Defendants waive their right to a hearing on their Anti-SLAPP Motion within 30 || days of filing the Motion. STIPULATED AND AGREED TO: DATED: December 2, 2015 GALLO LLP By: Detmtic— Yel = Dominic Valerian Attomeys for Plaintiff DATED: December 2, 2015 KINSELLA WEITZMAN ISER KUMP & ALDISERT LLP By: Howard Weitzman W/P20—".gio0n Attomeys for Defendants John Branca, as Co- Executor of the Estate of Michael J. Jackson, ‘Sony Music Entertainment and MJJ Productions, Inc. ‘STIPULATION REGARDING HEARING ON ANTI- ‘SLAPP MOTION Sowa su kw a 13 14] 15 16 | 17 18 19 20 a] 22 23 m4 25 26 27 DATED: December 2, 2015 / DATED: December 2, 2015 IT IS SO ORDERED. DATED: 28 | KATTEN MUCHIN ROSE} LLP By:_) Qemte— Fok Zia F. Modabber_ w/ Pe CTs $h0-~ Attomeys for Defendants John Branca, as Co- Executor of the Estate of Michael J. Jackson, Sony Music Entertainment and MJJ Productions, Inc. FREEDMAN AND TAITELMAN, LLP By: Foe. Bryan J. Freedman wy ‘Atiomeys for Defendants Edward Joseph Cascio, James Victor Porte, and Angelikson Productions, Ine. THE HONORABLE JANE L. JOHNSON ‘STIPULATION REGARDING HEARING ON ANTI- SLAPP MOTION i yh 5 a! 53 B 5 10 il 12 2B 14 15 16 17 18 19 20 21 22 23 24 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA ) ) ss. COUNTY OF MARIN ) Lam over the age of 18 years and not a party to this action, My business address is 1299 Fourth St,, Suite 505, San Rafael, CA 94901. My address for electronic service is amecarthy@gallo-law.com, On December 2, 2015, I served true and correct copies of the following document(s): STIPULATION AND [PROPOSED] ORDER REGARDING DEFENDANTS? PROPOSED ANTI-SLAPP MOTION By the following means of service: _X_: By CASE ANYWHERE/E-MAIL TRANSMISSION ~ I caused the above document(s) to be electronically served on counsel of record at 2:4()a.m.G.m) Pacific Time by using the electronic notification service www.caseanywhere.com and the e-mail addresses maintained on the Service List of www.caseanywhere.com for this case as follows: _ Howard Weitzman, hweitzman@kwikalaw.com Suann C. Maclsaac, smacisaac@kwikalaw.com KINSELLA WEITZMAN ISER KUMP & ALDISERT LLP 808 Wilshire Blvd. 3rd Floor Santa Monica, CA 90401 Phone: (310) 566-9800 Fax: (310) 566-9850 | Zia F, Modabber, zia. modabber@kattenlaw.com Andrew J, Demko, andrew.demko@kattenlaw.com) KATTEN MUCHIN ROSENMAN LLP 2029 Century Park East, Suite 2600 Los Angeles, CA 90067 Phone: (310) 788-4400 Fax: (310) 788-4471 ~__ | Attorneys for Defendants Sony Music Entertainment; MJJ Productions, Inc.; and John | Branca, as co-executor of the Estate of Michael J. Jackson Autorneys for Defendants Sony Music Entertainment; MJJ | Productions, Inc.; and John Branca, as co-executor of the Estate of Michael J. Jackson Bryan J. Freedman, bireedman@fillp.com Jordan Susman, jsusman@fillp.com | Sean M. Hardy, smhardy@fllp.com FREEDMAN AND TAITELMAN, LLP 1901 Avenue of the Stars, Suite 500 | Los Angeles, CA 90067 | Phone: (310) 201-0005 Fax: (310) 201-0045 Aitorneys for Defendants Edward Joseph Cascio, James Victor Porte, and Angelikson Productions LLC Page 1 PROOF OF SERVICE Gallo LLP 1299 Fourth St., Suite $05 ‘San Rafael, CA 94901 | Ray E. Gallo, rgallo@gallo-law.com Dominic Valerian, dvalerian@gallo-law.com GALLO LLP | 1299 Fourth St., Suite 505 | San Rafael, CA 94901 Phone: (415) 257-8800 Fax: (415) 257-8844 _ _ | | ‘Attorneys for Plaintiff Vera Serova | I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on December 2, 2015, at San Rafael, California. C—O ‘Amanda McCarthy PROOF OF SERVICE _