Baranco v. Ford Motor Company et al

Filing 22

STIPULATION AND ORDER re 21 STIPULATION WITH PROPOSED ORDER re 18 Amended Complaint, 10 Case Management Scheduling Order, Joint Stipulation and Proposed Order to Continue the Case Management Conference and Extend Defendant's Time to Respond to Plaintiffs' Am filed by Ford Motor Company. Case Management Statement due by 11/14/2017. Initial Case Management Conference set for 11/21/2017 10:00 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 8/31/17. (bpfS, COURT STAFF) (Filed on 8/31/2017)

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1 DYKEMA GOSSETT LLC Tamara A. Bush (197153) 2 tbush@dykema.com 333 South Grand Avenue, Suite 3100 3 Los Angeles, CA 90071 Telephone: (213) 457-1800 (213) 457-1850 4 Facsimile: 5 DYKEMA GOSSETT PLLC John M. Thomas (266842,) 6 jthomas@dykema.com 2723 South State Street, Suite 400 7 Ann Arbor, MI 48104 Telephone: (734) 214-7613 (734) 214-7696 8 Facsimile: 9 Attorneys for Defendant FORD MOTOR COMPANY 10 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN FRANCISCO DIVISION 14 DAVID BARANCO, JAMES ABBITT, HARRIET ABRUSCATO, DONALD 15 BROWN, DANIEL CARON, ANITA FARRELL, JOHN FURNO, JAMES 16 JENKIN, ROGER KINNUNEN, GARY KUBBER and MALISA NICOLAU, 17 individually and on behalf of all others similarly situated, 18 19 20 Plaintiffs, vs. FORD MOTOR COMPANY, a 21 Delaware corporation; 22 Defendants. Case No. 3:17-CV-03580-EMC Assigned to Hon. Edward M. Chen, Courtroom 5 – San Francisco JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE CASE MANAGEMENT CONFERENCE AND EXTEND DEFENDANT’S TIME TO RESPOND TO PLAINTIFFS’ AMENDED COMPLAINT Complaint Filed: June 21, 2017 1st Amend Complaint: August 18, 2017 Trial Date: None 23 24 Plaintiffs and Defendant FORD MOTOR COMPANY (“Ford”) (collectively 25 the “Parties”), by and through their respective counsel, hereby stipulate as follows: 26 WHEREAS, Plaintiff David Baranco filed a putative class action complaint in 27 the Northern District of California, San Francisco Division, on June 21, 2017 (the 1 28 JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE CASE MANAGEMENT CONFERENCE AND EXTEND DEFENDANT’S TIME TO RESPOND TO PLAINTIFFS’ AMENDED COMPLAINT CASE NO. 3:17-CV-03580 1 “Original Complaint”); WHEREAS, upon stipulation of the parties, Ford’s time to respond to the 2 3 Original Complaint was extended to August 25, 2017; WHEREAS, on July 10, 2017, the Court entered a Case Management Order 4 5 setting a case management conference for September 21, 2017; WHEREAS, on August 18, 2017, before any response to the Original 6 7 Complaint was filed, Plaintiffs filed a First Amended Class Action Complaint 8 (“Amended Complaint”), which added ten additional plaintiffs from 7 additional 9 states; 10 WHEREAS, Ford’s response to the Amended Complaint is currently due on 11 September 1, 2017; 12 WHEREAS, due to a trial in another matter for Ford’s counsel and the 13 additional number of Plaintiffs and claims asserted in the Amended Complaint, Ford 14 has requested and Plaintiffs have agreed to extend Ford’s time to respond to the 15 Amended Complaint until October 16, 2017; 16 WHEREAS, the parties agree that adjourning the case management 17 conference to a date after Ford responds to the Amended Complaint is appropriate to 18 preserve judicial economy and the parties resources and to make the conference more 19 efficient and useful; and 20 WHEREAS, counsel for Defendant, as the filer of this document, attests that 21 concurrence in the filing of the document has been obtained from each of the other 22 signatories. 23 IT IS THEREFORE STIPULATED BETWEEN THE PARTIES THAT: 24 1. The last day for Ford to file a response to Plaintiffs’ Amended 25 Complaint in the above-entitled action shall be October 16, 2017; and 26 27 28 1 JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE CASE MANAGEMENT CONFERENCE AND EXTEND DEFENDANT’S TIME TO RESPOND TO PLAINTIFFS’ AMENDED COMPLAINT CASE NO. 3:17-CV-03580 1 2. The Case Management Conference set for September 21, 2017 shall be 2 adjourned and reset to a new date after October 16, 2017, which shall be determined 3 by the Court pursuant to its schedule. 4 Dated: August 30, 2017 DYKEMA GOSSETT LLC 5 6 By: /s/ Tamara A. Bush John M. Thomas Tamara A. Bush Attorneys for Defendant FORD MOTOR COMPANY 7 8 9 10 11 Dated: August 30, 2017 BLOOD HURST & O’REARDON LLP 12 13 14 By: /s/ Timothy G. Blood Timothy G. Blood Leslie E. Hurst Attorneys for Plaintiff s 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE CASE MANAGEMENT CONFERENCE AND EXTEND DEFENDANT’S TIME TO RESPOND TO PLAINTIFFS’ AMENDED COMPLAINT CASE NO. 3:17-CV-03580 [PROPOSED] ORDER 1 2 Having reviewed the Parties’ Joint Stipulation and [Proposed] Order 3 Concerning Time to File Response to Amended Complaint and Adjourning the Case 4 Management Conference, and for good cause appearing, IT IS HEREBY 5 ORDERED THAT: 6 1. Defendant Ford Motor Company’s response to Plaintiffs’ Amended 7 Complaint in the above-entitled action shall be continued from September 1, 2017 to 8 October 16, 2017; and 9 2. The Case Management Conference set for September 21, 2017 is 10:00 a.m. November 21, 2017 10 adjourned and reset to _________________________ at 9:30 a.m. in Courtroom 5. 11 19 ER R NIA Chen FO dw Judge E H 18 RT 17 ard M. NO 16 A A 15 By: ________________________________ ERED O ORD D HON. EDWARD M. CHEN IT IS S I UNITED FIE S MOD STATES DISTRICT JUDGE LI 14 DATED:________________ UNIT ED 8/31/17 S DISTRICT TE C TA RT U O 13 S 12 IT IS SO ORDERED. N F D IS T IC T O R C 20 21 22 23 24 25 26 27 28 1 JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE CASE MANAGEMENT CONFERENCE AND EXTEND DEFENDANT’S TIME TO RESPOND TO PLAINTIFFS’ AMENDED COMPLAINT CASE NO. 3:17-CV-03580

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