Houghtailing v. Frito-Lay North America, Inc. et al
Filing
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STIPULATION AND ORDER to Continue Further Case Management Conference re 21 : Case Management Statement due by 6/4/2012. Further Case Management Conference set for 6/11/2012 at 1:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 04/09/2012. (tmi, COURT STAFF) (Filed on 4/10/2012)
1 DuCHARME & COHEN
JAMES A. DuCHARME, ESQ., SBN 61002
2 E-MAIL: jducharme@pacbell.net
450 Taraval Street, P.M.B. 317
3 San Francisco, CA 94116-2530
Telephone: 415.495.4171
4 Facsimile: 888.668.4170
5 Attorneys for Plaintiff
JESSE HOUGHTAILING
6
VILLARREAL HUTNER & TODD PC
7 TRACY S. TODD, ESQ., SBN 172884
E-Mail: ttodd@vhattorneys.com
8 JULIE WONG, ESQ., SBN 247342
E-Mail: jwong@vhtattorneys.com
9 575 Market Street, Suite 300
San Francisco, California 94105
10 Telephone: 415.543.4200
Facsimile: 415.512.7674
11
Attorneys for Defendants
12 FRITO-LAY NORTH AMERICA, INC. and
PEPSICO, INC.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION
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17 JESSE HOUGHTAILING,
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Plaintiff,
v.
20 FRITO-LAY NORTH AMERICA, INC., and
PEPSICO, INC., AND DOES 1 TO 100,
21 inclusive,
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Defendants.
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CASE NO. 3:11-cv-05062-TEH
Judge: Hon. Thelton E. Henderson
STIPULATION AND REQUEST TO
CONTINUE FURTHER CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER GRANTING
CONTINUANCE
Action Filed: August 24, 2011
Removal Filed: October 14, 2011
Trial Date: None Set
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{100011275}
CASE NO. 3:11-cv-05062-TEH
STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE
1
TO THIS HONORABLE COURT:
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Plaintiff Jesse Houghtailing (hereinafter "Plaintiff"), by and through his counsel, and
3 Defendants Frito-Lay North America, Inc. and Pepsico, Inc. ("Defendants"), by and through their
4 counsel, do hereby agree, stipulate, and respectfully request as follows:
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1.
WHEREAS, the further case management conference in this case is currently
6 scheduled for Monday, April 30, 2012 at 1:30 p.m., before the Court;
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2.
WHEREAS, Defendants subpoenaed Plaintiff's medical records on or about
8 February 24, 2012 for production on March 23, 2012;
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3.
WHEREAS, Defendants have not received the entirety of the subpoenaed
10 documents to date;
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4.
WHEREAS, the parties have agreed and Defendant Frito-Lay North America, Inc.
12 has noticed Plaintiff's deposition for May 10, 2012. The parties tried, but were unable to agree to
13 an earlier date due to scheduling conflicts;
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5.
WHEREAS, the parties believe that it would be most productive to conduct the
15 further case management conference after Defendant has deposed Plaintiff;
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6.
WHEREAS Plaintiff and his counsel have another case before this Court, Jesse
17 Houghtailing v. Crown Equipment Corp., Case Number 311-cv-05040-TEH, and the further case
18 management conference for that matter is also currently scheduled for April 30, 2012 at 1:30 p.m.;
19 and
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7.
WHEREAS counsel for Crown Equipment also agrees to a continuance of the
21 further case management conference because it too has discovery that is currently outstanding;
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8.
THE PARTIES HEREBY STIPULATE to continue the currently scheduled further
23 case management conference from April 30, 2012 until June 11, 2012. The parties are also
24 available for a further case management conference on June 4, 2012.
25 //
26 //
27 //
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{100011275}
CASE NO. 3:11-cv-05062-TEH
-1STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE
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IT IS SO STIPULATED.
2 Dated: April 5, 2012
DuCHARME & COHEN
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/s/ James A. DuCharme
JAMES A. DuCHARME
By
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Attorneys for Plaintiff
JESSE HOUGHTAILING
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Dated: April 6, 2012
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VILLARREAL HUTNER & TODD PC
/s/ Julie Wong
TRACY S. TODD
JULIE WONG
By
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Attorneys for Defendants
FRITO-LAY NORTH AMERICA, INC.
and PEPSICO, INC.
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15 ATTESTMENT OF CONCURRENCE PER GENERAL ORDER 45 FOR FILING:
I attest that concurrence in the filing of this document by the signatory James A.
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17 Du Charme, has been obtained, and that a record of the concurrence shall be maintained by
18 Villarreal Hutner & Todd PC.
I declare under penalty of perjury pursuant to the laws of the United States of
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America that the foregoing is true and correct.
Executed at San Francisco, California this 6th day of April, 2012.
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/s/ Julie Wong
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JULIE WONG
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{100011275}
CASE NO. 3:11-cv-05062-TEH
-2STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE
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[PROPOSED] ORDER
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Having considered the foregoing stipulation of the parties, the Court orders the
further case management conference in the instant matter, Houghtailing v. Frito-Lay North
America, Inc., et al., case number 3:11-cv-05062-TEH, continued to June 11, 2012, at 1:30 p.m. in
Courtroom 12. The parties shall meet and confer and file a joint case management conference
statement on or before June 4, 2012.
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IT IS SO ORDERED.
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S
April 9
Dated: _________________, 2012
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ODIFIE
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HON. THELTON
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CASE NO. 3:11-cv-05062-TEH
-3STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE
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