Horne v. Nissan North America, Inc.

Filing 31

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 1/10/2018 GRANTING an Extension of Time for the following deadlines: Fact Discovery due by 2/27/2018; Expert Witness Disclosure due by 4/30/2018; Rebuttal Expert Disclosure due by 5/30/2018; and Dispositive Motions due by 8/27/2018. The parties shall submit another proposed order reflecting the new discovery deadlines after the ruling on NNAs Motion to Dismiss and Motion to Transfer is issued. (Hunt, G)

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SHOOK, HARDY & BACON L.L.P.
Amir Nassihi (SBN 235936)
[e-mail]
One Montgomery, Suite 2700
San Francisco, California 94104-4505
Tel: [phone] | Fax: [phone]
Attorneys for Defendant
NISSAN NORTH AMERICA, INC.
FINKELSTEIN & KRINSK LLP
Jeffrey R. Krinsk (SBN 109234)
[e-mail]
Lauren R. Presser (SBN 292497)
[e-mail]
550 West C. St., Suite 1760
San Diego, California 94101
Tel: [phone] | Fax: [phone]
Attorneys for Plaintiffs
JANELLE HORNE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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JANELLE HORNE, individually and on behalf
of all others similarly situated,

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Plaintiffs,

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Case No. 2:17-cv-00436-MCE-DB
STIPULATION AND ORDER TO
CONTINUE DISCOVERY CUT-OFF AND
OTHER PRETRIAL DEADLINES

v.
NISSAN NORTH AMERICA, INC., NISSAN
MOTOR CO., LTD.
Defendants.

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This Stipulation is entered into by and between Plaintiff Janelle Horne and Defendant Nissan

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North America, Inc. (“NNA”) (collectively, the “Parties”),1 by and through their respective counsel,

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with reference to the following facts and recitals:

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represents NNA, not NML.

Defendant Nissan Motor Co. Ltd. (“NML”) has not yet appeared and undersigned counsel solely

STIPULATION AND ORDER TO CONTINUE DISCOVERY CUT-OFF
CASE NO. 2:17-CV-00436-MCE-DB
396698 V1

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Proceedings. (Dkt. 19);

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On August 16, 2017, NNA filed its Motion to Transfer, or in the alternative, to Stay

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Plaintiff filed her Oppositions to these motions on September 7, 2017. (Dkt. 21 and

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On September 29, 2017, NNA filed its Reply Briefs in support of its Motions to

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Dismiss and Transfer. (Dkt. 25 and 26);
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On October 16, 2017, the court vacated the hearing date on NNA’s Motion to Dismiss

and Motion to Transfer. (Dkt. 29)
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The Initial Pretrial Scheduling Order (Dkt. 5) currently contemplates the following

deadlines:
Event
Fact Discovery Cut-Off
Expert Witness Disclosures Due
Rebuttal Expert Disclosures Due
Dispositive Motions Due

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Current Deadline
February 27, 2018
April 30, 2018
May 30, 2018
August 27, 2018

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IT IS HEREBY STIPULATED by and between the parties, through their respective counsel, that

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the deadlines set forth above shall be continued and shift to begin starting six months from the date

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of the court’s rulings on NNA’s Motion to Dismiss and Motion to Transfer.

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Dated: January 9, 2018

SHOOK, HARDY & BACON L.L.P.
By:

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/s/ Amir Nassihi___________
Amir Nassihi

Attorneys for Defendant
NISSAN NORTH AMERICA, INC.

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Dated: January 9, 2018

FINKELSTEIN & KRINSK LLP
By: /s/ Lauren R. Presser (as authorized on 1/9/18)
Lauren R. Presser

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Attorneys for Plaintiff
JANELLE HORNE

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STIPULATION AND ORDER TO CONTINUE DISCOVERY CUT-OFF
AND OTHER PRETRIAL DEADLINES
CASE NO. 2:17-cv-00436-MCE-DB
396698 v1

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ORDER

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The parties’ above-referenced stipulation is hereby GRANTED. The parties shall submit

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another proposed order reflecting the new discovery deadlines after the ruling on NNA’s Motion to

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Dismiss and Motion to Transfer is issued.

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IT IS SO ORDERED.
Dated: January 10, 2018

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STIPULATION AND ORDER TO CONTINUE DISCOVERY CUT-OFF
AND OTHER PRETRIAL DEADLINES
CASE NO. 2:17-cv-00436-MCE-DB
396698 v1