`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`MIAMI DIVISION
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`CASE NO. 1:23-cv-22933-RKA
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`WORLD MEDIA ALLIANCE LABEL
`INC.,
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`vs.
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`ELLO ENTERTAINMENT GROUP, LLC,
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`VAL SEGAL,
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`YOUTUBE, LLC,
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`and GOOGLE LLC,
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`
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`__________________________________________/
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`JOINT MOTION BY PLAINTIFF WORLD MEDIA ALLIANCE LABEL INC. AND
`DEFENDANTS YOUTUBE, LLC AND GOOGLE LLC FOR EXTENSION OF TIME TO
`RESPOND TO PLAINTIFF’S COMPLAINT
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`Plaintiff World Media Alliance Label Inc. (“Plaintiff”) and Defendants Google LLC
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`Plaintiff,
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`Defendants.
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`(“Google”) and YouTube, LLC (“YouTube”), pursuant to Rule 6(b) of the Federal Rules of Civil
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`Procedure and Southern District of Florida Local Rule 7.1, hereby jointly move this Court for an
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`extension of Google and YouTube’s time to respond to Plaintiff’s Complaint (D.E. 1), and in
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`support state as follows:
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`1.
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`2.
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`3.
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`Plaintiff filed the Complaint on August 6, 2023.
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`On September 27, 2023, Plaintiff served the Complaint on Google and YouTube.
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`On January 21, 2024, following the parties’ January 18, 2024 status conference,
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`the Court issued an order extending Google and YouTube’s deadline to respond to the Complaint
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`Museum Tower 150 West Flagler Street, Suite 2200 Miami, FL 33130 (305) 789-3200
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`Case 1:23-cv-22933-RKA Document 57 Entered on FLSD Docket 02/21/2024 Page 2 of 4
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`until February 26, 2024. D.E. 56. The January 21 Order also directed “Plaintiff to give the
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`Defendants an itemized list specifying ALL of the allegedly infringed songs and videos, as well
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`as the associated copyright information, by February 1, 2024.” Id.
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`4.
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`Pursuant to the January 21 Order and the Court’s instructions at the January 18
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`status conference, Plaintiff’s counsel is engaging in good-faith discussions with counsel for the
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`various Defendants, including Defendants Ello and Segal, in an effort to resolve Plaintiff’s
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`claims without the need for further motion practice. No agreement has been reached as of today,
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`though discussions remain ongoing. To accommodate these ongoing discussions, Plaintiff’s
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`counsel agreed to an additional 30-day extension for Google and YouTube to respond to the
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`Complaint, up to and including March 27, 2024.
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`5.
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`This motion is made in good faith and without the purpose of delay.
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`WHEREFORE, Google, YouTube, and Plaintiff respectfully request that this Court
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`grant this Agreed Motion and enter the proposed Order attached hereto as Exhibit A, allowing
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`Google and YouTube up to and including March 27, 2024, within which to respond to the
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`Complaint.
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`Museum Tower 150 West Flagler Street, Suite 2200 Miami, FL 33130 (305) 789-3200
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`2
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`Case 1:23-cv-22933-RKA Document 57 Entered on FLSD Docket 02/21/2024 Page 3 of 4
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`Dated: February 21, 2024
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`
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`
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`/s/ George Lambert
`George Lambert, Esq.
`The Lambert Law Firm
`FL bar 1022697
`421 Poinciana Drive, #1422,
`Sunny Isles Beach, FL 33160
`Email: office.law.323@gmail.com
`Tel. (305) 938 0600
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`Attorney for Plaintiff World Media
`Alliance Label Inc.
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`Respectfully submitted,
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`
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`By: /s/ Jay B. Shapiro
`JAY B. SHAPIRO
`Florida Bar No. 776361
`jshapiro@stearnsweaver.com
`VERONICA L. DE ZAYAS
`Florida Bar No. 91284
`vdezayas@stearnsweaver.com
`STEARNS WEAVER MILLER WEISSLER
` ALHADEFF & SITTERSON, P.A.
`Museum Tower, Suite 2200
`150 West Flagler Street
`Miami, FL 33130
`Telephone: (305) 789-3200
`Facsimile: (305) 789-3395
`
`BRIAN WILLEN (pro hac vice)
`bwillen@wsgr.com
`JEREMY AUSTER (pro hac vice)
`jauster@wsgr.com
`WILSON SONSINI GOODRICH & ROSATI
`1301 6th Ave, #40
`New York, NY 10019
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`Attorneys for Defendants YouTube, LLC and
`Google LLC
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`Museum Tower 150 West Flagler Street, Suite 2200 Miami, FL 33130 (305) 789-3200
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`3
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`Case 1:23-cv-22933-RKA Document 57 Entered on FLSD Docket 02/21/2024 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that on February 21, 2024, the foregoing document was
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`electronically filed and served on all counsel of record via transmission of Notices of
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`Electronic Filing generated by CM/ECF.
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`/s/ Jay B. Shapiro
`Jay B. Shapiro
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`Museum Tower 150 West Flagler Street, Suite 2200 Miami, FL 33130 (305) 789-3200
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`4
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