Opinion
3:22-cv-00243-ART-CLB
08-02-2022
STEPHEN MASSA, Plaintiff v. FORD MOTOR COMPANY; and DOES 1 to 10, Defendants
CLINE APC, Brian Kelly Cline, Esq., Julian Daniel Lopez, Esq., Mark Anthony Johnson, Esq. Attorneys for Plaintiff Dawn L. Davis, Esq., Christian P. Ogata, Esq. SNELL & WILMER L.L.P. Attorneys for Defendant Ford Motor Company
CLINE APC, Brian Kelly Cline, Esq., Julian Daniel Lopez, Esq., Mark Anthony Johnson, Esq. Attorneys for Plaintiff
Dawn L. Davis, Esq., Christian P. Ogata, Esq. SNELL & WILMER L.L.P. Attorneys for Defendant Ford Motor Company
STIPULATION AND ORDER TO EXTEND TIME TO FILE JOINT CASE MANAGEMENT REPORT (SECOND REQUEST)
Plaintiff Stephen Massa and defendant Ford Motor Company, through their counsel of record, for good cause shown, stipulate to extend the parties' deadline to file their joint case management report to September 1, 2022, for the following reasons:
1. On January 12, 2022, Massa filed his complaint against Ford in the Superior Court of the State of California for the County of San Diego, North County.
ECF No. 1-3 (complaint).
2. Ford removed the action to the United States District Court for the Southern District of California on March 11, 2022.
ECF No. 1 (notice of removal).
3. Massa amended his complaint on April 15, 2022, which Ford answered on April 29, 2022.
ECF No. 8 (amended complaint).
ECF No. 11 (answer).
4. The same day, the parties jointly moved to change venue to the District of Nevada.
ECF No. 9 (joint motion).
5. Judge Anthony J. Battaglia of the Southern District of California granted the transfer motion and transferred this action to the District of Nevada on May 19, 2022.
ECF No. 13 (order granting joint motion).
6. On June 2, 2022, this Court ordered the parties to file their joint case management report.
ECF No. 17 (order to file case management report).
7. On July 7, 2022, this Court granted the parties' stipulation to extend the deadline to file their joint case management report because the parties had recently retained new counsel in Nevada. This is thus the second request to extend the deadline to file the joint case management report.
ECF No. 22 (order granting stipulation).
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.
9. Massa is in the process of locating new Nevada counsel for this matter and thus require additional time to retain new counsel and review the relevant documents to meaningfully meet and confer and inform this Court about the items required by this Court's order.
10. The parties agreed to this extension.
11. The extension request is sought in good faith and is not made for the purpose of delay.
Therefore, the parties respectfully request an extension to file their joint case management report in this matter up to and including September 1, 2022.
ORDER
Good cause appearing, IT IS HEREBY ORDERED that the parties shall file their joint case management report on or before September 1, 2022.
IT IS SO ORDERED.