Snyder et al v. Ford Motor Company

Filing 144

STIPULATION AND ORDER REVISING SCHEDULE REGARDING DISPOSITIVE MOTIONS. Plaintiffs' opposition to defendant's motion for summary judgment shall be filed no later than May 26, 2009, defendant's reply shall be filed no later than June 23, 2009, and the hearing on the motion shall be on July 17, 2009. Signed by Judge Maxine M. Chesney on February 18, 2009. (mmclc2, COURT STAFF) (Filed on 2/18/2009)

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Jeffrey L. Fazio (146043) ([e-mail]) Dina E. Micheletti (184141) ([e-mail]) FAZIO | MICHELETTI LLP 2410 Camino Ramon, Suite 315 San Ramon, CA 94583 T: 925-543-2555 F: 925-369-0344 Attorneys for Plaintiffs Robert Smith and Rebecca Klein, on behalf of themselves and all others similarly situated Warren E. Platt (154086) ([e-mail]) Robert J. Gibson (144974) ([e-mail]) Snell & Wilmer LLP 600 Anton Blvd., Suite 1400 Costa Mesa, CA 92626-7689 T: 714-427-7000 F: 714-427-7799 Attorneys for Defendant Ford Motor Company Additional Counsel Listed on Signature Page UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

RICHARD SMITH AND REBECCA KLEIN, on behalf of themselves and all others similarly situated, Plaintiffs, v. FORD MOTOR COMPANY, and DOES 1100, inclusive, Defendants.

Case No. C 06 0497 MMC JL STIPULATION AND PROPOSED ORDER REVISING SCHEDULE REGARDING DISPOSITIVE MOTIONS

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At the conclusion of the case management conference ("CMC") the Court instructed the parties' counsel to discuss the matter further following the CMC in an effort to resolve it in light of the Stipulation and Order Regarding Dispositive Motion Schedule that the Court issued on August 19, 2008. The parties' counsel complied with the Court's instructions and have agreed to resolve their discovery dispute (either informally or by filing a motion with Magistrate Larson) and to request that the Court adopt the schedule set forth below.

Accordingly, the parties have stipulated to the following schedule and hereby submit it to the Court for adoption as an order:

May 11, 2009

Plaintiffs conclude discovery pertaining to issues raised by Defendant's motions for summary judgment (including depositions of Defendant's declarants). Plaintiffs file briefs in opposition to motions for summary judgment and (possibly) cross-motion for summary judgment. Defendant completes depositions of Plaintiffs' declarants. Defendant files reply brief(s) in support of motions for summary judgment. Hearing of motion for summary judgment. 1

May 26, 2009

June 9, 2009 June 23, 2009

July 17, 2009

In the event that Plaintiffs file a cross-motion for summary judgment, the parties' shall, no later than five days thereafter, submit a stipulated revised briefing schedule in which the proposed hearing date on both motions shall be no earlier than three weeks after plaintiffs' reply is filed.
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-1STIPULATION AND PROPOSED ORDER REVISING SCHEDULE RE DISPOSITIVE MOTION
(NO. 3:06-CV-0497-MMC)

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SO STIPULATED.

DATED: February 16, 2009 by

FAZIO | MICHELETTI LLP /s/ Jeffrey L. Fazio Jeffrey L. Fazio Michael von Loewenfeldt Michael Ng KERR & WAGSTAFFE LLP 100 Spear Street, Suite 1800 San Francisco, CA 94105­1528 T: 415-371-8500 F: 415-371-0500 Attorneys for Plaintiffs Robert Smith and Rebecca Klein, on behalf of themselves and all others similarly situated

DATED: February 16, 2009

SNELL & WILMER LLP

by

/s/ Robert J. Gibson Robert J. Gibson

Attorneys for Defendant Ford Motor Company

SO ORDERED.

DATED: February 18

, 2009

Hon. Maxine M. Chesney United States District Judge

-2STIPULATION AND PROPOSED ORDER REVISING SCHEDULE RE DISPOSITIVE MOTION
(NO. 3:06-CV-0497-MMC)