Margie Daniel et al v. Ford Motor Company

Filing 167

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 08/22/17 ORDERING the following modifications to the Pretrial Order: exchange of final trial exhibit lists by 09/05/17 with oppositions due 09/08/17; Plaintiff's exhibits wil l be identified by the letter P placed before the number, and Defendants exhibits identified by the letter D placed before number; the deposition and interrogatory designation filing/serving requirements are waived; the parties will submit their evidentiary objections to deposition counter-designations on 09/05/17. (Benson, A.)

Download PDF
DYKEMA GOSSETT LLP 333 SOUTH GRAND AVENUE, SUITE 2100 LOS ANGELES, CA 90071 1 DYKEMA GOSSETT LLP JOHN M. THOMAS, SBN: 266842 2 jthomas@dykema.com TAMARA A. BUSH, SBN: 197153 3 tbush@dykema.com FRED J. FRESARD (Pro Hac Vice) 4 ffresard@dykema.com KRISTA L. LENART (Pro Hac Vice) 5 klenart@dykema.com JANET CONIGLIARO (Pro Hac Vice) 6 jconigliaro@dykema.com BRITTANY J. MOUZOURAKIS (Pro Hac Vice) 7 bmouzourakis@dykema.com 333 South Grand Avenue, Suite 2100 8 Los Angeles, California 90071 Telephone: (213) 457-1800 (213) 457-1850 9 Facsimile: 10 ORRICK NORMAN HILE, SBN: 57299 11 nhile@orrick.com 400 Capitol Mall, Suite 3000 12 Sacramento, California 95814-4497 13 Attorneys For Defendant FORD MOTOR CO. 14 15 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 16 SACRAMENTO DIVISION 17 MARGIE DANIEL, ROBERT McCABE, 18 MARY HAUSER, DONNA GLASS, and ANDREA DUARTE, individually and on behalf 19 of a class of similarly situated individuals, Plaintiffs, 20 21 Case No. 2:11-cv-02890-WBS –EFB Honorable William B. Shubb STIPULATED SUGGESTED MODIFICATIONS TO PRETRIAL ORDER vs. 22 FORD MOTOR COMPANY, a Delaware corporation, 23 Defendant. 24 25 26 27 28 STIPULATED REQUEST TO MODIFY DATES OTHER THAN DATE OF TRIAL 1 2 STIPULATED SUGGESTED MODIFICATIONS TO PRETRIAL ORDER Defendant and Plaintiff have conferred telephonically to discuss suggested modifications 3 pursuant to Section XV of the Court’s Final Pretrial Order dated August 15, 2017 [DE #163]. 4 Exhibits C and D to the Pretrial Order identify the exhibits Plaintiff and Defendant intend to offer at 5 trial, respectively. Both parties agree that the exhibits listed in Exhibits C and D will likely change 6 7 as the parties continue to confer in an attempt to reduce the number of exhibits and refine and 8 amend their trial exhibit lists. As such, both parties have agreed to exchange their final trial exhibit 9 lists no later than September 5, 2017, the date of exhibit exchange. Objections to exhibits will DYKEMA GOSSETT LLP 333 SOUTH GRAND AVENUE, SUITE 2100 LOS ANGELES, CA 90071 10 remain due on September 8, 2017. 11 12 13 Also, because both parties recognize that each party will be offering numerous exhibits at trial, the parties agree that for the ease of the Court, the parties, and the jury, it would be more practical to have Plaintiffs’ exhibits identified by the letter “P” placed before the number, and 14 15 Defendant’s exhibits identified by the letter “D” placed before the number, as opposed to 16 Defendant’s exhibits being labeled solely by letter as instructed in Section VIII.(H). 17 Finally, Section X of the Final Pretrial Order requires that on August 23, 2017 (20 days 18 before trial), both parties must file and serve deposition designations and interrogatory answer 19 20 designations. Section X also requires that on September 5, 2017 (10 days before trial), deposition counter-designations and objections to the other party’s designations are due. The parties have 21 22 23 already filed and exchanged deposition designations and counter-designations in their Pretrial Conference Statements, and are conferring in an effort to resolve objections and pare down the 24 amount of video deposition testimony that will be presented at trial. Neither party intends to 25 designate interrogatory answers. Accordingly, the parties request that the August 23rd and 26 September 5th deposition and interrogatory designation filing/serving requirements be waived. The 27 parties will submit their evidentiary objections to deposition counter-designations on September 5, 28 STIPULATED REQUEST TO MODIFY DATES OTHER THAN DATE OF TRIAL 1 2017 (5 days before the trial date). 2 3 Both parties respectfully ask the Court to incorporate these suggested modifications into the Pretrial Order. 4 5 Dated: August 22, 2016 6 Respectfully submitted, 7 DYKEMA GOSSETT LLP 8 By: /s/John M. Thomas JOHN M. THOMAS (Bar No. 266842) TAMARA A. BUSH (Bar No. 197153) KRISTA L. LENART (pro hac vice) 333 South Grand Avenue, Suite 2100 Los Angeles, California 90071 Telephone: (213) 457-1800 Facsimile: (213) 457-1850 9 DYKEMA GOSSETT LLP 333 SOUTH GRAND AVENUE, SUITE 2100 LOS ANGELES, CA 90071 10 11 12 13 FRED J. FRESARD (pro hac vice) 39577 Woodward Avenue, Suite 300 Bloomfield Hills, Michigan 48304 Telephone: (248) 203-0700 Facsimile: (855) 233-1801 14 15 16 Attorneys for Defendant FORD MOTOR COMPANY 17 18 /s/John B. Thomas (as authorized on August 22, 2017) John B. Thomas Hicks Thomas LLP 19 20 21 J. Allen Carney Hank Bates Carney Bates & Pulliam, PLLC 22 23 Attorneys for Plaintiff MARGIE DANIEL 24 25 SO ORDERED. 26 Dated: August 22, 2017 27 28 STIPULATED REQUEST TO MODIFY DATES OTHER THAN DATE OF TRIAL

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?