Brightbill et al v. General Motors, LLC

Filing 33

JOINT STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE. The Case Management Conference currently set for April 15, 2016, is continued to May 13, 2016. Signed by Judge Maxine M. Chesney on March 30, 2016. (mmclc2, COURT STAFF) (Filed on 3/30/2016)

1 DYKEMA GOSSETT LLP

Derek S. Whitefield (SBN: 165731)

2 [e-mail]

Dommond E. Lonnie (SBN: 142662)

3 [e-mail]

Isabella C. Hsu (SBN: 306178)

4 [e-mail]

333 South Grand Avenue, Suite 2100

5 Los Angeles, CA 90071

Telephone: [phone]

6 Facsimile: [phone]
7 Attorneys for Defendant,

GENERAL MOTORS, LLC

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DYKEMA GOSSETT LLP

UNITED STATES DISTRICT COURT

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333 SOUTH GRAND AVENUE, SUITE 2100
LOS ANGELES, CA 90071

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

12 JOEL BRIGHTBILL and PATRICIA

Case No. 3:15-cv-03789-MMC

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[Assigned to Hon. Maxine M. Chesney]

PAYEUR,

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Plaintiffs,
vs.
GENERAL MOTORS, LLC, (A.K.A

16 "NEW GM") AND DOES 1-100,

JOINT STIPULATION AND
[PROPOSED] ORDER TO
CONTINUE CASE MANAGEMENT
CONFERENCE

Defendants.

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IT IS HEREBY STIPULATED by and between Plaintiffs Joel Brightbill and

20 Patricia Payeur and Defendant General Motors LLC (collectively referred to as “the
21 Parties”), by and through their attorneys of record, as follows:
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1.

The Parties have exchanged Rule 26 initial disclosures and participated

23 in a full day of mediation on March 28, 2016 in San Jose with mediator Charles
24 Hawkins. Substantial progress was made at the mediation but a settlement was not
25 reached. The Parties agreed at the conclusion of the mediation to continue settlement
26 discussions for the next 30 days.
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2.

The parties believe there is a reasonable likelihood of resolving this case

28 through continued settlement discussions. Good cause therefore exists to continue

1 the Case Management Conference (CMC), currently set for April 15, 2016 at 10:30
2 a.m. to avoid the time and expense associated with preparing the CMC report and
3 appearing at the conference.
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3.

Accordingly, the parties stipulate and request that the court continue the

5 CMC to May 13, 2016 at 10:30 a.m. If the case has not settled, the Parties will file a
6 CMC Statement at least one week prior to the continued CMC date. If the case
7 settles between now and then, the parties will notify the Court that the CMC can be
8 taken off calendar.
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4.

The Parties also agree that, should any of the above-referenced proposed

DYKEMA GOSSETT LLP

333 SOUTH GRAND AVENUE, SUITE 2100
LOS ANGELES, CA 90071

10 dates be inconvenient or unacceptable for any reason, the Court has the discretion to
11 set other dates which are more convenient or acceptable. However, counsel request
12 that, in any event, the current proposed dates in this matter be continued to a time that
13 is at least after May 13, 2016.
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15 Dated: March 30, 2016

DYKEMA GOSSETT LLP

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20 Dated: March 30, 2016

By:/s/ Derek S. Whitefield
Derek S. Whitefield
Attorneys for Defendant,
GENERAL MOTORS, LLC
LAW OFFICES OF BONNER & BONNER

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By:/s/ Charles A. Bonner
Charles A. Bonner
Attorneys for Plaintiffs,
JOEL BRIGHTBILL AND
PATRICIA PAYEUR

1 I hereby attest that I have on file all holographic signatures corresponding to any
2 signatures indicated by a conformed signature (/S/) within this e-filed document.
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Dated: March 30, 2016

DYKEMA GOSSETT LLP

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By:/s/ Derek S. Whitefield
Derek S. Whitefield
Attorneys for Defendant,
GENERAL MOTORS, LLC

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DYKEMA GOSSETT LLP

333 SOUTH GRAND AVENUE, SUITE 2100
LOS ANGELES, CA 90071

10 PURSUANT TO STIPULATION, IT IS SO ORDERED
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12 Dated: Mar. 30 2016
______,
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United States District Judge