Snyder et al v. Ford Motor Company

Filing 152

ORDER EXTENDING FILING AND HEARING DATES REGARDING FORD'S MOTIONS FOR SUMMARY JUDGMENT. Plaintiffs' opposition shall be filed no later than July 6, 2009, defendant's reply shall be filed no later than August 10, 2009, and the hearing will be on September 4, 2009. Signed by Judge Maxine M. Chesney on June 30, 2009. (mmclc2, COURT STAFF) (Filed on 6/30/2009)

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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

ROBERT SMITH AND REBECCA SMITH, 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 EXTENDING FILING AND HEARING DATES REGARDING FORD'S MOTIONS FOR SUMMARY JUDGMENT

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Due to unanticipated events that were outside the control of Plaintiffs' counsel, Plaintiffs require a brief extension of time to prepare and file their opposition to Defendant Ford Motor Company's motions for summary judgment. Ford has agreed to an extension of up to six calendar days for the filing of Plaintiffs' opposition if Ford obtains a reciprocal extension of six calendar days for the filing of Ford's reply papers. Plaintiffs have agreed to Ford's proposal. Accordingly, the parties hereby submit the following stipulation for the Court's approval:

July 6, 2009 July 27, 2009 August 10, 2009 September 4, 2009

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 motions for summary judgment. 1

SO STIPULATED. DATED: June 29, 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

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 EXTENDING MSJ BRIEFING AND HEARING SCHEDULE
(NO. 3:06-CV-0497-MMC)

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DATED: June 29, 2009

SNELL & WILMER LLP

by

/s/ Robert J. Gibson Robert J. Gibson

Attorneys for Defendant Ford Motor Company SO ORDERED.

DATED: June 30

, 2009

Hon. Maxine M. Chesney United States District Judge

-1STIPULATION AND PROPOSED ORDER EXTENDING MSJ BRIEFING AND HEARING SCHEDULE
(NO. 3:06-CV-0497-MMC)