Pierson v. Scott et al

Filing 268

STIPULATION AND ORDER TO STAY JUDGMENT re 267 Stipulation filed by Ford Motor Company. Signed by Judge Phyllis J. Hamilton on 8/26/09. (nah, COURT STAFF) (Filed on 8/26/2009)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

H. GRANT LAW (SBN: 144505) [e-mail] AMIR NASSIHI (SBN: 235936) [e-mail] SHOOK, HARDY & BACON L.L.P. 333 Bush Street, Suite 600 San Francisco, California 94104-2828 Telephone: [phone] Facsimile: 415.391.0281 Attorneys for Defendant FORD MOTOR COMPANY DANIEL DELL'OSSO (SBN: 118203) [e-mail] LAW OFFICES OF THOMAS J. BRANDI 354 Pine Street, Third Floor San Francisco, CA 94104 Telephone: [phone] Facsimile: 415.989.1801 Kevin F. Quinn, Esq. (SBN: 106224) [e-mail] TORNSNES BARTOLOTTA MCGUIRE 2550 Fifth Avenue, Suite 1100 San Diego, CA 92103 Telephone: [phone] Facsimile: 619.236.9653 Attorney for Plaintiff DAX PIERSON UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA DAX PIERSON, Plaintiff, vs. FORD MOTOR COMPANY, Defendant. ) Case No. CV-06-06503 PJH ) ) ) JOINT MOTION AND STIPULATION TO ) STAY JUDGMENT; [PROPOSED] ORDER ) ) ) ) ) )

Plaintiff Dax Pierson and Defendant Ford Motor Company have met and conferred with respect to staying the judgment and execution or enforcement thereof, pending conclusion of posttrial and appellate proceedings in this matter. Although Fed. R. Civ. Proc. Rule 62(a)'s 10 day stay
1 JOINT MOTION AND STIPULATION RE STAYING JUDGMENT PENDING CONCLUSION OF APPEAL; [PROPOSED] ORDER CV-06-06503 PJH

165827V1

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

after entry of judgment falls on September 1, 2009, Parties have agreed that Ford may post its bond of $15,227,000, by September 4, 2009. The judgment and execution or enforcement thereof are stayed until the conclusion of post-trial and appellate proceedings in this matter, as if Ford's bond was approved by this Court before September 1, 2009.

Date: August 25, 2009

Respectfully Submitted, SHOOK, HARDY & BACON, L.L.P. By:_/s/_ H. Grant Law_______ H. GRANT LAW Attorney for Defendant FORD MOTOR COMPANY THE BRANDI LAW FIRM. By:_/s/_ Kevin F. Quinn_____ KEVIN F. QUINN, Attorney for Plaintiff DAX PIERSON

[PROPOSED] ORDER Pursuant to stipulation, the Court hereby orders the following: Enforcement or execution of the judgment in this matter are hereby stayed pending conclusion of post-trial and appellate proceedings, subject to Ford posting its bond by September 4, 2009.
S
ISTRIC ES D TC AT T

IT IS SO ORDERED. 8/26/09 DATED: _______________________

RT U O

The Honorable Phyllis iJ.on Hamilton lt
ER
A

N

2

F D IS T IC T O R

C

165827V1

JOINT MOTION AND STIPULATION RE STAYING JUDGMENT PENDING CONCLUSION OF APPEAL; [PROPOSED] ORDER CV-06-06503 PJH

LI

FO

Judge P

Ham hyllis J.

R NIA

ERED O ORD IT IS S ______________________________
NO

UNIT ED

RT

H