Filed: Aug. 12, 2016
Latest Update: Aug. 12, 2016
Summary: STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND TO EXTEND TIME FOR DEFENDANT FORD MOTOR COMPANY TO RESPOND TO FIRST AMENDED COMPLAINT JON S. TIGAR , District Judge . Pursuant to Civil L.R. 6-2, counsel of record for Plaintiff Michael Sullivan, Defendant Ford Motor Company ("Ford") and Defendant Thieman Tailgates, Inc. (collectively "the Parties") hereby stipulate to: (1) continue the Initial Case Management Conference currently scheduled for Octobe
Summary: STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND TO EXTEND TIME FOR DEFENDANT FORD MOTOR COMPANY TO RESPOND TO FIRST AMENDED COMPLAINT JON S. TIGAR , District Judge . Pursuant to Civil L.R. 6-2, counsel of record for Plaintiff Michael Sullivan, Defendant Ford Motor Company ("Ford") and Defendant Thieman Tailgates, Inc. (collectively "the Parties") hereby stipulate to: (1) continue the Initial Case Management Conference currently scheduled for October..
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND TO EXTEND TIME FOR DEFENDANT FORD MOTOR COMPANY TO RESPOND TO FIRST AMENDED COMPLAINT
JON S. TIGAR, District Judge.
Pursuant to Civil L.R. 6-2, counsel of record for Plaintiff Michael Sullivan, Defendant Ford Motor Company ("Ford") and Defendant Thieman Tailgates, Inc. (collectively "the Parties") hereby stipulate to:
(1) continue the Initial Case Management Conference currently scheduled for October 5, 2016 at 2:00pm to November 9, 2016 at 2:00 pm or as soon thereafter as is convenient for the Court.
(2) Continue the corresponding deadlines accordingly as follows:
a. 10/19/16 — Last day to complete Rule 26(f) conference.
b. 10/31/16 — Last day to file Joint CMC Statement.
c. 11/2/16 — Deadline to exchange initial disclosures and to submit Rule 26(f) Report.
(3) continue the following ADR selection process deadlines as set forth in the Court's June 24, 2016 Order by 30 days.
Plaintiff Michael Sullivan and Ford further stipulate to extend Ford's deadline to respond to Plaintiff's First Amended Complaint from August 15, 2016 to September 6, 2016.
As set forth in the accompanying declaration of Joan R. Camagong, good cause exists to continue the Initial Case Management Conference due to Plaintiff's counsel's trial conflict. Further, good cause also exists to extend Ford's deadline to respond to Plaintiff's First Amended Complaint as it raises complex legal issues that require additional time for Ford to prepare its response.
There have been no prior time modifications in this case.
The Parties believe that continuing the Initial Case Management Conference and all corresponding deadlines triggered by the Initial Case Management Conference will not prejudice the Parties at this stage of the litigation.
SIGNATURE ATTESTATION
I, Joan R. Camagong, am the ECF User whose ID and password are being used to file this STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND TO EXTEND TIME FOR DEFENDANT FORD MOTOR COMPANY TO RESPOND TO FIRST AMENDED COMPLAINT. In compliance with Local Rule 5-1(i), I hereby attest that Plaintiff's counsel and Defendant Thieman Tailgates, Inc.'s counsel have concurred in this filing.
DATED: August 10, 2016 SHOOK, HARDY & BACON, L.L.P.
By: /s/Joan R. Camagong
____________________________
JOAN R. CAMAGONG
Attorneys for Defendant
FORD MOTOR COMPANY
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
