Massa v. Ford Motor Company et al

Filing 24

ORDER granting ECF No. #23 Stipulation to Extend Time : The parties shall file their joint case management report on or before 9/1/2022. Signed by Magistrate Judge Carla Baldwin on 8/2/2022. (Copies have been distributed pursuant to the NEF - DRM)

Case 3:22-cv-00243-ART-CLB Document 24 Filed 08/02/22 Page 1 of 4

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Dawn L. Davis, Esq.
Nevada Bar No. 13329
Christian P. Ogata, Esq.
Nevada Bar No. 15612
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: 702.784.5252
Email:
[e-mail]
[e-mail]
Attorneys for Defendant Ford Motor Company

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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STEPHEN MASSA,

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Plaintiff

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vs.
FORD MOTOR COMPANY; and DOES 1 to
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Defendants

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Case No.: 3:22-cv-00243-ART-CLB
Stipulation and Order to Extend Time to
File Joint Case Management Report
(Second Request)

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Plaintiff Stephen Massa and defendant Ford Motor Company, through their counsel of

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record, for good cause shown, stipulate to extend the parties’ deadline to file their joint case

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management report to September 1, 2022, for the following reasons:
1.

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of the State of California for the County of San Diego, North County.1
2.

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On January 12, 2022, Massa filed his complaint against Ford in the Superior Court

Ford removed the action to the United States District Court for the Southern District

of California on March 11, 2022.2

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ECF No. 1-3 (complaint).

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ECF No. 1 (notice of removal).

Case 3:22-cv-00243-ART-CLB Document 24 Filed 08/02/22 Page 2 of 4

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3.
29, 2022.4

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4.

The same day, the parties jointly moved to change venue to the District of Nevada.5

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5.

Judge Anthony J. Battaglia of the Southern District of California granted the transfer

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motion and transferred this action to the District of Nevada on May 19, 2022.6

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L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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On June 2, 2022, this Court ordered the parties to file their joint case management

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On July 7, 2022, this Court granted the parties’ stipulation to extend the deadline to

report.7

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Snell & Wilmer

Massa amended his complaint on April 15, 2022,3 which Ford answered on April

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file their joint case management report because the parties had recently retained new counsel in

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Nevada.8 This is thus the second request to extend the deadline to file the joint case management

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report.

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8.

Counsel for Ford emailed Massa’s counsel on July 25, 2022, and July 27, 2022, to

schedule the court-ordered meet and confer about the topics in the case-management report.

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9.

Massa is in the process of locating new Nevada counsel for this matter and thus

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require additional time to retain new counsel and review the relevant documents to meaningfully

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meet and confer and inform this Court about the items required by this Court’s order.

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10.

The parties agreed to this extension.

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11.

The extension request is sought in good faith and is not made for the purpose of

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delay.

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///

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ECF No. 8 (amended complaint).

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ECF No. 11 (answer).

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ECF No. 9 (joint motion).

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ECF No. 13 (order granting joint motion).

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ECF No. 17 (order to file case management report).

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ECF No. 22 (order granting stipulation).

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Case 3:22-cv-00243-ART-CLB Document 24 Filed 08/02/22 Page 3 of 4

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Therefore, the parties respectfully request an extension to file their joint case management
report in this matter up to and including September 1, 2022.

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Dated: August 1, 2022

Dated: August 1, 2022

CLINE APC

SNELL & WILMER L.L.P.

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By: /s/ Brian Kelly Cline
Brian Kelly Cline, Esq.
Julian Daniel Lopez, Esq.
Mark Anthony Johnson, Esq.
7855 Ivanhoe Ave., Suite 408
La Jolla, CA 92037

By: /s/ Christian Ogata
Dawn L. Davis, Esq.
Christian P. Ogata, Esq.
3883 Howard Hughes Parkway, Ste. 1100
Las Vegas, Nevada 89169

Attorneys for Plaintiff

Attorneys for Ford Motor Company

Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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ORDER
Good cause appearing, IT IS HEREBY ORDERED that the parties shall file their joint
1 2022.
case management report on or before September
_________,

IT IS SO ORDERED.

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UNITED STATES MAGISTRATE JUDGE
DATED: August 2, 2022

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Case 3:22-cv-00243-ART-CLB Document 24 Filed 08/02/22 Page 4 of 4

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CERTIFICATE OF SERVICE

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I hereby certify that on August 1, 2022 I electronically transmitted the foregoing document

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to the Clerk’s Office using the CM/ECF System for filing and transmittal of a Notice of Electronic

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Filing to all counsel in this matter; all counsel being registered to receive Electronic Filing.

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/s/ Lyndsey Luxford
An employee of SNELL & WILMER L.L.P.

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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