Tracy Yu-Santos v. Ford Motor Company et al

Filing 90

JOINT STIPULATION Requesting Continuation of Trial Date, Pretrial Conference and All Currently Scheduled and Statutorily Scheduled Dates for Six Weeks; ORDER, signed by Magistrate Judge Dennis L. Beck on 12/18/2009. (Jury Trial set for 4/20/2010 at 09:00 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii and Pretrial Conference set for 2/19/2010 at 08:30 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii) (Martin, S)

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SQUIRE, SANDERS & DEMPSEY L.L.P.
555 SO. FLOWER STREET, SUITE 3100 LOS ANGELES, CA 90071-2300

Adam R. Fox (State Bar # 220584) [e-mail] Anne Choi Goodwin (State Bar # 216244) [e-mail] Helen H. Yang (State Bar # 241170) [e-mail] SQUIRE, SANDERS & DEMPSEY L.L.P. 555 South Flower Street, Suite 3100 Los Angeles, CA 90071 Telephone: [phone] Facsimile: +1.213.623.4581 Attorneys for Defendant TRW VEHICLE SAFETY SYSTEMS INC. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

TRACY YU-SANTOS, Plaintiff, vs. FORD MOTOR COMPANY, TRW AUTOMOTIVE HOLDINGS CORP., TRW AUTOMOTIVE INC., TRW AUTOMOTIVE U.S. LLC, TRW VEHICLE SAFETY SYSTEMS INC., ROBERT SANTOS, and DOES 1 through 10, Defendants.

Case No. 1:06-cv-01773-AWI-DLB JOINT STIPULATION REQUESTING CONTINUATION OF TRIAL DATE, PRETRIAL CONFERENCE AND ALL CURRENTLY SCHEDULED AND STATUTORILY SCHEDULED DATES FOR SIX WEEKS; ORDER THEREON Assigned to: Judge: Hon. Anthony W. Ishii

The parties to this action, Plaintiff Tracy Yu-Santos ("Yu-Santos") and Defendant TRW Vehicle Safety Systems Inc. ("TRW VSSI"), by and through their respective undersigned counsel, hereby enter into the following stipulation: /// /// /// /// ///
JOINT STIPULATION REQUESTING CONTINUATION OF TRIAL DATE AND ALL ASSOCIATED DATES

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SQUIRE, SANDERS & DEMPSEY L.L.P.
555 SO. FLOWER STREET, SUITE 3100 LOS ANGELES, CA 90071-2300

WHEREAS, on July 28, 2009, this Court held a Telephonic Scheduling Conference in this case, setting the Trial Commencement Date for March 9, 2010 at 9:00 a.m. and the Pretrial Conference for January 8, 2010 at 8:30 a.m.; WHEREAS, TRW VSSI's lead trial counsel in this matter Adam Fox, has requested Plaintiff's counsel's stipulation to a brief adjournment of the trial commencement date because his wife is pregnant and expecting a natural childbirth (and thus, not a scheduled delivery) of their first child on or about February 4, 2010, and Mr. Fox would like to be with his family at the time of the birth and avoid any prolonged separation from them during the first several weeks thereafter, and the distractions attendant to final pretrial preparations; WHEREAS, Plaintiff has stipulated and agreed to such an adjournment of the trial commencement date for six (6) weeks, from March 9, 2010 to April 20, 2010, but would oppose any further or longer continuance than to April 20, 2010; WHEREAS, a call to the clerk of the Court has indicated the availability of the Honorable Anthony W. Ishii, United States District Judge, to commence the trial in this matter on April 20, 2010; WHEREAS, Plaintiff's lead trial counsel in this matter David Wright is currently scheduled to commence trial in another case on January 12, 2010 in Phoenix, Arizona, and upon agreeing to a six-week adjournment of the trial commencement date, made of Mr. Fox the independent request for a commensurate six week continuance of the Pretrial Conference from January 8, 2010 to February 19, 2010; WHEREAS, TRW VSSI has stipulated and agreed to a six-week continuance of the Pretrial Conference from January 8, 2010 to February 19, 2010. NOW, THEREFORE, THE PARTIES HEREBY AGREE AND STIPULATE, subject to the approval of the Court, to an adjournment of the trial commencement date currently scheduled for March 9, 2010 to April 20, 2010, or such other date in between the two referenced dates as this case may be heard by this Court. The parties also stipulate to a continuance of the Pretrial Conference such that the Pretrial Conference -1Proof of Service

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SQUIRE, SANDERS & DEMPSEY L.L.P.
555 SO. FLOWER STREET, SUITE 3100 LOS ANGELES, CA 90071-2300

currently scheduled for January 8, 2010 is continued to February 19, 2010, or any other such date commensurate with the new trial date selected by the Court. The parties further stipulate that all dates triggered thereby, including but not limited to deadlines set forth in Rule 281 (PRETRIAL STATEMENTS) and all other statutory pretrial deadlines will be moved accordingly. IT IS THEREFORE STIPULATED AND AGREED that 1. The Trial Commencement date shall be continued from March 9, 2010 at

9:00 a.m. to April 20, 2010 at 9:00 a.m., or such other date as is set by this Court; 2. The Pretrial Conference shall be continued from January 8, 2010 at 8:30

a.m. to February 19, 2010 at 8:30 a.m., or such other date stemming from the new trial date. 3. All associated dates in this matter, specifically including the deadlines set

forth in Rule 281 (PRETRIAL STATEMENTS) and all other statutory pretrial deadlines will be calculated based on the new Trial Commencement date and Pretrial Conference date. IT IS SO STIPULATED. Dated: December 16, 2009 SQUIRE, SANDERS & DEMPSEY L.L.P. By: /s/Adam R. Fox Adam R. Fox Anne Choi Goodwin Helen H. Yang Attorneys for Defendant TRW VEHICLE SAFETY SYSTEMS INC. Dated: December 16, 2009 MCCUNE & WRIGHT, LLP By: /s/David C. Wright David C. Wright Kristy M. Arevalo Attorneys for Plaintiff TRACY YU-SANTOS

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JOINT STIPULATION EXTENDING TIME TO FILE RESPONSIVE PLEADING

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SQUIRE, SANDERS & DEMPSEY L.L.P.
555 SO. FLOWER STREET, SUITE 3100 LOS ANGELES, CA 90071-2300

ORDER IT IS SO ORDERED. Dated:

December 18, 2009
DEAC_Si gna tur e - END:

/s/ Dennis

L. Beck

UNITED STATES MAGISTRATE JUDGE

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JOINT STIPULATION EXTENDING TIME TO FILE RESPONSIVE PLEADING