UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION
April 18, 2011
DONALD D. ALBEE, AS CONSERVATOR FOR THE PERSON AND ESTATE OF DONALD HAYES ALBEE, PLAINTIFF,
CONTINENTAL TIRE NORTH AMERICA, INC., AN OHIO CORPORATION AND FORD MOTOR COMPANY, INC., A DELAWARE CORPORATION, DEFENDANTS.
Robert F. Perez, Esq., CA #054301 Robert Gray Williams, Esq., CA #068033 PEREZ, WILLIAMS, MEDINA & RODRIGUEZ 1432 Divisadero Fresno, California 93721 Telephone: (559) 445-0123 Facsimile: (559) 445-1753 E-mail: firstname.lastname@example.org W. Randolph Barnhart, Esq., CO #5186 Admitted Pro Hac Vice W. RANDOLPH BARNHART, PC 50 South Steele Street, Suite 500 Denver, Colorado 80209 Telephone: (303) 377-6700 Facsimile: (303) 377-6705 E-mail: email@example.com John B. Gsanger, Esq., TX #00786662 Admitted Pro Hac Vice THE EDWARDS LAW FIRM 802 North Carancahua Street, Suite 1400 Corpus Christi, Texas 78401 Telephone: (361) 698-7660 Facsimile: (361) 698-7614 E-mail: firstname.lastname@example.org ATTORNEYS FOR PLAINTIFF Donald D. Albee, as Conservator for the Person and Estate of DONALD HAYES ALBEE
Date of Filing: January 12, 2009
Trial Date: July 6, 2011
STIPULATION AND ORDER
COMES NOW Donald D. Albee, as Conservator for the Person and Estate of Donald Hayes Albee ("Plaintiff") and Defendant Continental Tire North America, Inc. ("CTNA") by and through their respective counsel and enter the following Stipulation and Proposed Order:
1. Defendant CTNA began operating as Continental Tire the Americas, LLC, an Ohio Limited Liability Company with its principal place of business in South Carolina as of January 31, 2010.
2. Counsel for CTNA, Walter M. Yoka, and his law firm are also counsel for Continental Tire the Americas, LLC, an Ohio Limited Liability Company.
3. The parties have conferred and agreed there is no need to amend the caption in this matter because Continental Tire the Americas, LLC, an Ohio Limited Liability Company agrees that it will be bound by any judgment in this matter as if it had been a named party herein.
Wherefore, Plaintiff and CTNA and Continental Tire the Americas, LLC, an Ohio Limited Liability Company hereby agree and stipulate that any judgment entered herein against CTNA shall be deemed to be a judgment against Continental Tire the Americas, LLC, an Ohio Limited Liability Company and pray this Honorable Court to enter an Order hereon.
IT IS SO ORDERED.
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