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Jesse Houghtailing v. Crown Equipment Corporation.

April 10, 2012

JESSE HOUGHTAILING, PLAINTIFF,
v.
CROWN EQUIPMENT CORPORATION., AND DOES 1 TO 100, INCLUSIVE,
DEFENDANTS.



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

STIPULATION AND [PROPOSED] ORDER TO CONTINUE FURTHER CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER GRANTING CONTINUANCE Action Filed: August 3, 2011 Removal Filed: October 13, 2011 Trial Date: None Set

TO THIS HONORABLE COURT: 2

Plaintiff Jesse Houghtailing (hereinafter "Plaintiff"), by and through his counsel, and 3 Defendant Crown Equipment Corporation ("Defendant"), by and through its counsel, do hereby 4 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; 7

2. WHEREAS, Defendant subpoenaed third-party records on or about March 2, 2012 8 for production on March 16, 2012; 9

3. WHEREAS, Defendant has not received the entirety of the subpoenaed documents 10 to date; 11

4. WHEREAS review of the subpoenaed documents is necessary for Defendant to 12 supplement its initial disclosures and prepare for the deposition of Plaintiff; 13

4. WHEREAS Plaintiff and his counsel have another case before this Court, Jesse 14 Houghtailing v. Frito-Lay North America, Inc., et al., Case Number 311-cv-05062-TEH, and the 15 further case management conference for that matter is also currently scheduled for April 30, 2012 16 at 1:30 p.m.; and 17

5. WHEREAS, Defendant understands that the parties in Case Number 311-cv-18 05062-TEH have agreed and Defendant Frito-Lay North America, Inc. has noticed Plaintiff's 19 deposition for May 10, 2012; 20

6. WHEREAS, Defendant understands that the parties in Case Number 311-cv-21 05062-TEH have also requested a continuance of the April 30, 2012 further case management; 22

7. WHEREAS Defendant also agrees to a continuance of that further case 23 management conference because it has discovery that is currently outstanding; and 24

8. WHEREAS Defendant believes it would be efficient for both conferences to be 25 heard on the same day; 26

9. THE PARTIES HEREBY STIPULATE AND REQUEST that, subject to the 27

Court's availability and approval, the currently scheduled further case management conference be 28 continued from April 30, 2012 until June 11, 2012. The parties are also available for a ...


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