Tracy Yu-Santos v. Ford Motor Company et al

Filing 92

STIPULATION and ORDER continuing Pretrial Conference and deadline to file joint pretrial conference statement; the deadline to file the Joint Pretrial Conference Statement shall be continued from February 12, 2010 to February 19, 2010 the Pretrial Conference currently set for 2/19/2010 is continued to 2/26/2010 at 08:30 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii. Order signed by Chief Judge Anthony W. Ishii on 2/10/2010. (Timken, A)

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

David C. Wright, Esq. (State Bar No. 177468) [e-mail] Jae K. Kim, Esq. (State Bar No. 236805) [e-mail] McCuneWright, LLP 2068 Orange Tree Lane, Suite 216 Redlands, California 92374 Telephone: [phone] Facsimile: [phone] Attorneys for PLAINTIFF 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 PRETRIAL CONFERENCE AND DEADLINE TO FILE JOINT PRETRIAL CONFERENCE STATEMENT; ORDER THEREON Assigned to: Judge: Hon. Anthony W. Ishii

JOINT STIPULATION REQUESTING CONTINUATION OF PRETRIAL CONFERENCE AND ASSOCIATED DATE

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

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: WHEREAS, on December 18, 2009, this Court entered a Stipulation Requesting Continuation of Trial Date, Pretrial Conference and All Scheduled and Statutorily Scheduled Dates for Six Weeks, pursuant to which the Court continued the Pretrial Conference to February 19, 2010 at 08:30 a.m. and caused the deadline for the Joint Pretrial Conference Statement to move to February 12, 2010. WHEREAS, Plaintiff's lead trial counsel in this matter David Wright was scheduled to commence trial in another case on January 12, 2010 in Phoenix, Arizona, which did not commence until January 19, 2010 and which ended on January 29, 2010. WHEREAS, since early February 2010, and for the past week, the parties have been working together on a Joint Pretrial Conference Statement. On February 8, 2010, Plaintiff sent TRW VSSI a portion of her Joint Pretrial Conference Statement. However, due to the lengthy number of exhibits that the parties are actively compiling for their respective exhibit lists, and the number of factual and legal issues that the parties have yet to discuss, the parties stipulate to and respectfully request that the Court continue the Pretrial Conference from February 19, 2010 to February 26, 2010 and the deadline to file a Joint Pretrial Conference Statement from February 12, 2010 to February 19, 2010. WHEREAS, this stipulation does not seek to continue the trial commencement date, currently set for April 20, 2010. WHEREAS, a call to the clerk of the Court has indicated that the calendar for the Honorable Anthony W. Ishii, United States District Judge, for February 26, 2010 appears to be clear; /// /// ///
JOINT STIPULATION REQUESTING CONTINUATION OF PRETRIAL CONFERENCE AND ASSOCIATED DATE

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

NOW, THEREFORE, THE PARTIES HEREBY AGREE AND STIPULATE, subject to the approval of the Court, to a continuance of the Pretrial Conference such that the Pretrial Conference currently scheduled for February 19, 2010 is continued to February 26, 2010, or any other such date and time thereafter at the Court's convenience. The parties further stipulate that the deadline to file the Joint Pretrial Conference Statement triggered thereby will be moved accordingly from February 12, 2010 to February 19, 2010. IT IS THEREFORE STIPULATED AND AGREED that: 1. The Pretrial Conference shall be continued from February 19, 2010 at 8:30

a.m. to February 26, 2010 at 8:30 a.m., or any other such date and time thereafter at the Court's convenience. 2. The deadline to file the Joint Pretrial Conference Statement shall be

continued from February 12, 2010 to February 19, 2010. 3. Plaintiff will deliver the remaining portion of her Joint Pretrial Conference

Statement to TRW VSSI by February 12, 2010. TRW VSSI will deliver its portion of its Joint Pretrial Conference Statement to Plaintiff by February 17, 2010. The parties will conference on February 18, 2010 to resolve any disputed issues of fact or law and to finalize their Joint Pretrial Conference Statement. IT IS SO STIPULATED. [SIGNATURES ON FOLLOWING PAGE] /// /// ///

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JOINT STIPULATION REQUESTING CONTINUATION OF PRETRIAL CONFERENCE AND ASSOCIATED DATE

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

Dated: February 9, 2010

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. MCCUNE & WRIGHT, LLP /s/ David C. Wright David C. Wright Jae K. Kim Attorneys for Plaintiff TRACY YU-SANTOS By:

Dated: February 9, 2010

ORDER IT IS SO ORDERED. DATED: February 10, 2010 /s/ Anthony W. Ishii The Honorable Anthony W. Ishii UNITED STATES DISTRICT JUDGE

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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

PROOF OF SERVICE (Pursuant to Federal Law) The undersigned certifies and declares as follows: I am a resident of the State of California and over 18 years of age and am not a party to this action. My business address is 555 South Flower Street, Suite 3100, Los Angeles, CA 90071-2300, which is located in the county where any non-personal service described below took place.

On February 10, 2010, a copy of the following document(s):
JOINT STIPULATION REQUESTING CONTINUATION OF PRETRIAL CONFERENCE AND DEADLINE TO FILE JOINT PRETRIAL CONFERENCE STATEMENT; [PROPOSED] ORDER THEREON

Attorney for Plaintiff David C. Wright Kristy M. Arevalo McCune & Wright 2068 Orange Tree Lane, Suite 216 Redlands, CA 92374 [e-mail] [e-mail]

Via U.S. Mail Robert Santos, Pro Se Robert Santos 2049 65th Avenue Sacramento, CA 95822

Service was accomplished as follows. By U.S. Mail, According to Normal Business Practices. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice the mail would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at Los Angeles, California, in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid of postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. E-MAIL I caused the document(s) to be scanned and E-mailed to David C. Wright at [e-mail] and Kristy M. Arevalo at [e-mail]. I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. Executed on February 10, 2010 at Los Angeles, California. /s/Consuelo M. Lopez Consuelo M. Lopez
G:\PDFs\TRW\Yu-Santos\10 0209 WORD - Stipulation_and_Proposed_Order_to_Continue_Pretrial_Conference.DOC

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Proof of Service