Jackson v. Ford Motor Co.
Filing
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STIPULATION AND ORDER signed by District Judge Daniel J. Calabretta on 1/17/2025 GRANTING the parties' 43 Stipulation to Modify the Briefing Schedule re Defendant's 37 Motion to Dismiss; ORDERING Plaintiffs to file their response to Def endant's motion by 2/14/2025; ORDERING Defendant to file its reply, if any, by 3/14/2025; VACATING the motion hearing set for 3/20/2025; and RESETTING the matter for hearing on 4/3/2025 at 1:30 PM in Courtroom 7 before District Judge Daniel J. Calabretta. (Deputy Clerk GJM)
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Cody R. Padgett (SBN 275553)
cody.padgett@capstonelawyers.com
Nathan N. Kiyam (SBN 317677)
nate.kiyam@capstonelawyers.com
CAPSTONE LAW APC
1875 Century Park East, Suite 1000
Los Angeles, California 90067
Telephone: (310) 556-4811
Attorneys for Plaintiffs
KENNETH HUNNEL and LEANNE HUNNEL
Amir Nassihi (SBN 235936)
anassihi@shb.com
SHOOK HARDY & BACON L.L.P.
555 Mission Street, Suite 2300
San Francisco, CA 94105
Telephone: 415.544.1900
Facsimile: 415.391.0281
Attorneys for Defendant
FORD MOTOR COMPANY
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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KENNETH HUNNEL, LEANNE HUNNEL,
Individually and on behalf of all others
similarly situated,
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Plaintiffs,
v.
Case No.: 2:24-cv-00423-DJC-DB
JOINT STIPULATION AND ORDER
REGARDING BRIEFING SCHEDULE
ON DEFENDANT’S MOTION TO
DISMISS
FORD MOTOR COMPANY,
Defendant.
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STIPULATION AND ORDER
CASE NO. 2:24-CV-00423-DJC-AB
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Plaintiffs KENNETH HUNNEL AND LEANNE HUNNEL (“Plaintiffs”) and Defendant
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FORD MOTOR COMPANY (“Defendant” or “Ford”), collectively referred to as the “Parties,” by
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and through their respective counsel, have met and conferred regarding the briefing schedule
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(“Schedule”) as extended on Defendant’s motion to dismiss Plaintiff’s First Amended Class Action
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Complaint (“FAC”), and subject to Court approval and having agreed to further extend the Schedule,
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hereby stipulate as follows:
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1. On February 7, 2024, Plaintiff filed the original complaint (Dkt. 1); and
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2. On April 18, 2024, the Court granted Defendant’s L.R. 28-day extension to respond to June
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3, 2024 (Dkt. 15); and
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3. On May 24, 2024, and pursuant to the Parties’ Joint Status Report (Dkt. 16), the Court granted
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the Parties’ stipulation for Plaintiff to file an amended complaint on July 3, 2024 and for
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Defendant to respond on August 23, 2024 (Dkt. 19); and
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4. On July 3, 2024, the FAC was filed (Dkt. 28) which added new plaintiffs; and
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5. On September 13, 2024, Defendant filed a Motion to Dismiss (Dkt. 32); and
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6. On October 29, 2024, the Court permitted Defendant to withdraw its Motion to Dismiss
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without prejudice as to re-filing by November 25, 2024 while the Parties continued to meet
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and confer regarding their efforts to reach a resolution (Dkt. 36); and
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7. On November 25, 2024, Defendant filed the currently pending Motion to Dismiss and noticed
it for hearing on March 20, 2025 (Dkt. 37); and
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8. Plaintiffs’ response to the pending Motion to Dismiss was extended by stipulation and court
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order to January 17, 2025 (Dkt. 40), and Defendant’s reply was extended by stipulation and
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court order to February 19, 2025 (Dkt. 40); and
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9. On December 13, 2024, Plaintiff Stephen Jackson filed his Notice of Voluntary Dismissal
Without Prejudice (Dkt. 41); and
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10. In light of the recent changes to the case and such other discussions between the Parties, the
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Parties have conferred and have agreed to further extend the deadlines to the pending Motion
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to Dismiss as follows: Plaintiffs shall be permitted to file their response to the pending Motion
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STIPULATION AND ORDER
CASE NO. 2:24-CV-00423-DJC-AB
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to Dismiss on or before February 14, 2025, and Defendant shall be permitted to file its reply
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on or before March 14, 2025.
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IT IS SO STIPULATED AND AGREED.
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Dated: January 16, 2025
CAPSTONE LAW APC
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/s/ Nathan N. Kiyam
Cody R. Padgett
Nathan N. Kiyam
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Attorneys for Plaintiffs
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Dated: January 16, 2025
SHOOK, HARDY & BACON L.L.P.
/s/ Amir Nassihi (as authorized on 1/15/2025)
AMIR NASSIHI
Attorneys for Defendant
FORD MOTOR COMPANY
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STIPULATION AND ORDER
CASE NO. 2:24-CV-00423-DJC-AB
ATTESTATION OF SIGNATURE
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Pursuant to Civil L.R. 131(e), the undersigned hereby attests that concurrence in the filing
of this document has been obtained from all signatories hereto.
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Dated: January 16, 2025
/s/ Nathan N. Kiyam
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STIPULATION AND ORDER
CASE NO. 2:24-CV-00423-DJC-AB
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ORDER
The parties’ above-referenced stipulation is hereby GRANTED. Plaintiffs shall file their
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response to the pending Motion to Dismiss on or before February 14, 2025, and Defendant shall file
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its reply on or before March 14, 2025. Further, the Court VACATES the hearing on Defendant’s
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Motion to Dismiss, set for March 20, 2025, and RESETS the matter for hearing on April 3, 2025, at
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1:30 PM in Courtroom 7 before District Judge Daniel J. Calabretta.
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IT IS SO ORDERED.
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Dated: January 17, 2025
/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE
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STIPULATION AND ORDER
CASE NO. 2:24-CV-00423-DJC-AB
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