filed 11/15 and signed by judge on 11/15--

BASIS FOR REQUEST FOR EXTENSION

Plaintiff has been actively engaged in settlement related discussions with an apparent

authorized agent of lead defendant Yamaha Corporation that most likely will resolve this entire

case as to all of the Defendants. However, time is needed to continue such discussions and

resolve this matter if possible.

Additionally, given that Yamaha Corporation’s time to respond to the Complaint has

been extended to January 28, 2013 by operation of law and that most likely it will be and/or is

the lead defendant in this case, it may conserve judicial resources if the time for all the

Defendants to respond to the Complaint is similarly extended to the same date.

Further, one or more of the Defendants, to include but not limited to Sam Ash Music

Corporation and J & R Electronics may or does require an extension of time due to the

unforeseen circumstances caused by Hurricane/Storm “Sandy.”

With the above in mind, Plaintiff seeks an extension of time for all the Defendants to

respond to the Complaint not for delay, but to permit the parties an opportunity to resolve