Lozano et al v. Ford Motor Company

Filing 13

STIPULATION AND ORDER TO VACATE DEADLINES AND CASE MANAGEMENT CONFERENCE re 9 Stipulation filed by Ford Motor Company. Signed by Judge Phyllis J. Hamilton on 10/22/08. (nah, COURT STAFF) (Filed on 10/22/2008)

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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) hlaw@shb.com Amir Nassihi (SBN: 235936) anassihi@shb.com Mia Solvesson (SBN: 246291) msolvesson@shb.com SHOOK, HARDY & BACON L.L.P. 333 Bush Street, Suite 600 San Francisco, California 94104-2828 Telephone: (415) 544.-900 Facsimile: (415) 391-0281 Attorneys for Defendant FORD MOTOR COMPANY UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ROBERTO O. LOZANO, DANIEL GERARD, RAMON RODRIGUEZ, QU PING, AND NANCY KIGER, individually and on behalf of all others similarly situated, Plaintiffs, vs. FORD MOTOR COMPANY, Defendant. Complaint Filed: July 3, 2008 PJH Case No. CV 08 3244 MEJ STIPULATION AND [PROPOSED] ORDER TO VACATE DEADLINES AND CASE MANAGEMENT CONFERENCE On August 22, 2008, the Judicial Panel on Multidistrict Litigation ("JPML") issued Conditional Transfer Order 37 ("CTO-37") in In re Ford Motor Company Speed Control Deactivation Switch Products Liability Litigation, MDL No. 1718 ("MDL"). CTO-37 conditionally transfers the above-entitled action, Lozano, et al. v. Ford Motor Company, to the MDL in the Eastern District of Michigan and assigns it to the Honorable Bernard A. Friedman. Neither party opposes the conditional transfer order and, therefore, the parties expect that the transfer order shall become final shortly. 1 STIPULATION AND [PROPOSED] ORDER TO VACATE DEADLINES AND CASE MANAGEMENT CONFERENCE Case No. CV 08 3244 MEJ 146764v1 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 that: IT IS HEREBY STIPULATED, by and between the parties through their counsel of record, 1. All dates and/or deadlines currently set by the Court's July 3, 2008 Order Setting Initial Case Management Conference and ADR Deadlines should be vacated. 2. The October 9, 2008 Case Management Conference should be vacated. IT IS SO STIPULATED. Dated: October 1, 2008 CADDELL & CHAPMAN By: /s/ Cory S. Fein MICHAEL A. CADDELL CYNTHIA B. CHAPMAN CORY S. FEIN Attorneys for Plaintiffs SHOOK, HARDY & BACON L.L.P. By: /s/ Mia O. Solvesson_________ H. GRANT LAW AMIR NASSIHI MIA O. SOLVESSON Attorneys for Defendant FORD MOTOR COMPANY Dated: October 1, 2008 2 STIPULATION AND [PROPOSED] ORDER TO VACATE DEADLINES AND CASE MANAGEMENT CONFERENCE Case No. CV 08 3244 MEJ 146764v1 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 October 22 Dated:___________________, 2008 [PROPOSED] ORDER Pursuant to stipulation and GOOD CAUSE APPEARING, the Court hereby orders the following: 1. The September 18, 2008 deadlines to (1) meet and confer regarding initial disclosures, early settlement, ADR process selection, and discovery plan; (2) file ADR Certification; and (3) file either Stipulation to ADR Process or Notice of Need for ADR Phone Conference are hereby vacated. 2. The October 2, 2008 deadlines to (1) file Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report; and (2) file Case Management Statement are hereby vacated. 3. The Initial Case Management Conference, currently set for October 9, 2008 in Courtroom B on the 15th Floor in San Francisco at 10:00 a.m., is hereby vacated. IT IS SO ORDERED. UNIT ED _______________________________________ HONORABLE DISTRICTD ERE JUDGE S S DISTRICT TE C TA RT U O J ER N F D IS T IC T O R 3 STIPULATION AND [PROPOSED] ORDER TO VACATE DEADLINES AND CASE MANAGEMENT CONFERENCE Case No. CV 08 3244 MEJ 146764v1 A C LI FO yllis J. udge Ph Hamilto n R NIA O IT IS S ORD NO RT H

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