Reger et al v. Mountain Life Flight Inc. et al

Filing 26

STIPULATION and ORDER signed by Judge John A. Mendez on 2/6/12: The time for submission of the Joint Status Report be extended to within thirty (30) days of resolution of the pending motion to remand. (Kaminski, H)

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ROGER A. DREYER, ESQ. / SBN: 095462
STANLEY P. FLESHMAN, ESQ. / SBN: 061133
DREYER BABICH BUCCOLA WOOD CAMPORA,
20 Bicentennial Circle
Sacramento, CA 95826
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiffs

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LLP

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MEGAN REGER, individually, and as
Successor in Interest to Clinton Reger,
deceased; KEVIN EIKLEBERRY as
Guardian Ad Litem for EVAN REGER and
MATTHEW REGER, minors,

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Plaintiffs,

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v.

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Case No.: 2:11-CV-03301-JAM-DAD

JOINT STIPULATION AND MOTION
TO EXTEND TIME TO SUBMIT JOINT
STATUS REPORT

MOUNTAIN LIFEFLIGHT INC.; AMERICAN
EUROCOPTER LLC; LYCOMING ENGINES;
TEXTRON INC.; AVCO INC.; HONEYWELL
INTERNATIONAL COMPANY; TURBOMECA
USA; TURBOMECA ENGINE CORPORATION
and DOES 1 through 80,
Defendants.

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Pursuant to the Order Requiring Joint Status Report filed on December 12, 2011

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(Dkt. 5), the date to file the Joint Status Report appears to be February 7, 2012. The parties

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through their respective counsel have stipulated to an order to extend the date for filing of the

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Joint Status Report and request that the court so order an extension of time for filing of the

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Joint Status Report.

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The parties respectfully submit that good cause exists for the extension of time to file

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the Joint Status Report. This matter was removed from the California Superior Court in and for

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the County of Sacramento. There is currently a motion to remand pending, with a hearing on
Joint Stipulation and Motion

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that motion set for March 7, 2012. (Dkt. 17.) Plaintiffs anticipate filing an additional motion to

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remand shortly. Additionally, the court ordered this matter related to Ritz v. Mountain Lifeflight

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Inc et al., 2:12-CV-00134-KJM-CKD. (Dkt. 21.) That action likewise was removed from the

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California Superior Court in and for the County of Sacramento. It is anticipated that the

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plaintiffs in the Ritz case will file a motion to remand that action as well.

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During the meet and confer process on the Joint Status Report, counsel stipulated to

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this request to the court to continue the date for submission of the Joint Status Report to an

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appropriate time following determination of motions to remand to state court.

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action be remanded to state court, it will proceed there and the proceedings in this court will

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Should this

cease and the submission of a Joint Status Report will not be necessary.

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Therefore the parties move the court Pursuant to Local Rules 143(a) and (b) and 144(a)

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and any other applicable provision of the Local Rules for an order extending the time to submit

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the Joint Status Report to thirty (30) days from resolution of the issue of remand to the state

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court or such other date as the court deems appropriate.

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IT IS HEREBY STIPULATED by and between the parties to the above-captioned
action as follows:
That a Joint Status Report shall be filed within thirty (30) days of resolution of the

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pending motion to remand or such other date as the court deems appropriate.

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DATED: February 3, 2012

DREYER BABICH BUCCOLA WOOD CAMPORA,

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By:

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/s/ Roger Dreyer
ROGER A. DREYER
Attorneys for Plaintiffs

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DATED: February 3, 2012

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NIXON PEABODY, LLP

By:

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Joint Stipulation and Motion

/s/ Paul E. Stinson
PAUL E. STINSON
Attorneys for Defendant,
AMERICAN EUROCOPTER CORPORATION
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LLP

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DATED: February 3, 2012

PERKINS COIE LLP

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By:

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/s/ Joshua Reiten
JOSHUA REITEN
Attorneys for Defendants,
HONEYWELL INTERNATIONAL INC., TEXTRON
INC., AVCO CORPORATION, and LYCOMING
ENGINES

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DATED: February 3, 2012

CODDINGTON, HICKS & DANFORTH

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By:

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/s/ Randolph S. Hicks
RANDOLPH S. HICKS
Attorneys for Defendant,
MOUNTAIN LIFEFLIGHT, INC.

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IT IS SO ORDERED that the time for submission of the Joint Status Report be extended
to within thirty (30) days of resolution of the pending motion to remand.

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Dated: February 6, 2012

/s/ John A. Mendez_________
U.S. DISTRICT COURT JUDGE

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Joint Stipulation and Motion

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