Filed: Sep. 10, 2014
Latest Update: Sep. 10, 2014
Summary: JOINT STIPULATION AND [PROPOSED] ORDER SETTING SCHEDULE FOR MOTION TO TRANSFER AND CONTINUING CASE MANAGEMENT CONFERENCE JON S. TIGAR, District Judge. WHEREAS, Defendants Toyota Motor North America, Inc. and Toyota Motor Sales, U.S.A., Inc. intend to move to transfer this action to the Central District; WHEREAS, due to deadlines in other matters, vacation plans, and holiday-related commitments, counsel for Plaintiff Annita Emerson requested, and Defendants agreed, to a briefing schedule
Summary: JOINT STIPULATION AND [PROPOSED] ORDER SETTING SCHEDULE FOR MOTION TO TRANSFER AND CONTINUING CASE MANAGEMENT CONFERENCE JON S. TIGAR, District Judge. WHEREAS, Defendants Toyota Motor North America, Inc. and Toyota Motor Sales, U.S.A., Inc. intend to move to transfer this action to the Central District; WHEREAS, due to deadlines in other matters, vacation plans, and holiday-related commitments, counsel for Plaintiff Annita Emerson requested, and Defendants agreed, to a briefing schedule ..
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JOINT STIPULATION AND [PROPOSED] ORDER SETTING SCHEDULE FOR MOTION TO TRANSFER AND CONTINUING CASE MANAGEMENT CONFERENCE
JON S. TIGAR, District Judge.
WHEREAS, Defendants Toyota Motor North America, Inc. and Toyota Motor Sales, U.S.A., Inc. intend to move to transfer this action to the Central District;
WHEREAS, due to deadlines in other matters, vacation plans, and holiday-related commitments, counsel for Plaintiff Annita Emerson requested, and Defendants agreed, to a briefing schedule whereby Plaintiff's response to the Motion to Transfer will not be filed until October 7, 2014;
WHEREAS, pursuant to Civil Local Rules 6-1(b) and 6-2, the parties have agreed, subject to the Court's approval, to the following briefing and hearing schedule on Defendants' Motion to Transfer: (a) Defendants' Motion to Transfer and all supporting papers will be filed by September 12, 2014; (b) Plaintiff's Opposition and all supporting papers will be filed by October 7, 2014; (c) Defendants' Reply brief and all supporting papers will be filed by October 28, 2014; and (d) the hearing on Defendants' Motion to Transfer will occur on November 13, 2014, at 2:00 p.m., or the next day available for the Court; and
WHEREAS, the parties also stipulate and respectfully request that the Court continue the date of the Case Management Conference from October 8, 2014, to the same date as the hearing on Defendants' Motion to Transfer (November 13, 2014).
WHEREAS, the parties respectfully submit that this brief continuance increases efficiency, and also is in the interests of judicial economy as the Court will have the benefit of Defendants' fully-briefed transfer motion before it proceeds to consider case scheduling issues, and the parties note that there have been no previous continuances of the Case Management Conference.
THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between counsel, and subject to the approval of this Court, that:
1. Defendants' Motion to Transfer and all supporting papers will be filed by September 12, 2014; Plaintiff's Opposition and all supporting papers will be filed by October 7, 2014; Defendants' Reply brief and all supporting papers will be filed by October 28, 2014; and the hearing on Defendants' Motion to Transfer will occur on November 13, 2014, at 2:00 p.m., or the next day available for the Court.
2. The Case Management Conference shall be continued to the same date as the hearing on Defendants' Motion to Transfer (November 13, 2014, or the next available date), and the parties shall submit a joint case management statement no later than October 30, 2014.
PROPOSED ORDER
Having considered the parties' Stipulation, and good cause appearing, the Court hereby GRANTS the parties' Stipulation. It is HEREBY ORDERED that:
1. Defendants' Motion to Transfer and all supporting papers will be filed by September 12, 2014; Plaintiff's Opposition and all supporting papers will be filed by October 7, 2014; Defendants' Reply brief and all supporting papers will be filed by October 28, 2014; and the hearing on Defendants' Motion to Transfer will occur on November 13, 2014, at 2:00 p.m., or the next day available for the Court.
2. The Case Management Conference shall be continued to the same date as the hearing on Defendants' Motion to Transfer (November 13, 2014, or the next available date), and the parties shall submit a joint case management statement no later than October 30, 2014.