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Jesse Houghtailing v. Frito-Lay North America

April 9, 2012

JESSE HOUGHTAILING,
PLAINTIFF,
v.
FRITO-LAY NORTH AMERICA, INC., AND GRANTING PEPSICO, INC., AND DOES 1 TO 100, INCLUSIVE,
DEFENDANTS.



The opinion of the court was delivered by: Judge: Hon. Thelton E. Henderson

Action Filed: August 24, 2011

STIPULATION AND REQUEST TO CONTINUE FURTHER CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER CONTINUANCE

Removal Filed: October 14, 2011

Trial Date: None Set

TO THIS HONORABLE COURT:

Plaintiff Jesse Houghtailing (hereinafter "Plaintiff"), by and through his counsel, and Defendants Frito-Lay North America, Inc. and Pepsico, Inc. ("Defendants"), by and through their 4 counsel, do hereby agree, stipulate, and respectfully request as follows: 5 1. WHEREAS, the further case management conference in this case is currently 6 scheduled for Monday, April 30, 2012 at 1:30 p.m., before the Court;

2. WHEREAS, Defendants subpoenaed Plaintiff's medical records on or about February 24, 2012 for production on March 23, 2012; 9

3. WHEREAS, Defendants have not received the entirety of the subpoenaed 10 documents to date; 11 12 has noticed Plaintiff's deposition for May 10, 2012. The parties tried, but were unable to agree to 13 an earlier date due to scheduling conflicts; 14 15 further case management conference after Defendant has deposed Plaintiff; 16

4. WHEREAS, the parties have agreed and Defendant Frito-Lay North America, Inc.

5. WHEREAS, the parties believe that it would be most productive to conduct the

6. WHEREAS Plaintiff and his counsel have another case before this Court, Jesse

Houghtailing v. Crown Equipment Corp., Case Number 311-cv-05040-TEH, and the further case 18 management conference for that matter is also currently scheduled for April 30, 2012 at 1:30 p.m.; 19 and 20

7. WHEREAS counsel for Crown Equipment also agrees to a continuance of the 21 further case management conference because it too has discovery that is currently outstanding; 22 23 case management conference from April 30, 2012 until June 11, 2012. The parties are also 24 ...


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