Perez v. Ford Motor Company ( 2023 )

1 DAVID N. BARRY, ESQ. (SBN 219230) ANNA H. GALAVIZ, ESQ. (SBN 293651) 2 THE BARRY LAW FIRM 11845 W. Olympic Blvd., Suite 1270 3 Los Angeles, CA 90064 Telephone: 310.684.5859 4 Facsimile: 310.862.4539 5 Attorneys for Plaintiff, GILBERTO PEREZ 6 H. PAUL EFSTRATIS (SBN 242373) 7 LEWIS BRISBOIS BISGAARD & SMITH LLP 45 Fremont Street, Suite 3000 8 San Francisco, California 94105 Telephone: 415.262.8592 9 Facsimile: 415.434.0882 10 Attorneys for Defendant FORD MOTOR COMPANY 11 UNITED STATES DISTRICT COURT 12 EASTERN DISTRICT OF CALIFORNIA 13 GILBERTO PEREZ, an individual, Case No. 2:22-cv-01380-DJC-DB 14 15 Plaintiff, (Removed from Sacramento County – Case No. 34-2022-00322216) 16 v. 17 STIPULATION FOR EXTENSION OF TIME TO FILE DISPOSITIONAL 18 FORD MOTOR COMPANY, A Delaware DOCUMENTS; ORDER 19 Corporation; and DOES 1 through 20, inclusive, 20 Defendants. Action Filed: June 21, 2022 21 Trial Date: None 22 District Judge: Hon. Daniel J. Calabretta 23 24 25 26 27 28 1 || TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD: 2 Plaintiff Gilberto Perez and Defendant Ford Motor Company (the “Parties”) filed a Joint 3 Notice of Settlement on December 2, 2022. [ECF 6.] Since filing of the Joint Notice of 4 || Settlement, the Parties have cooperated in completing the settlement terms. However, pursuant to 5 || the terms of the Parties’ settlement and despite the Parties due diligence, the Parties require a brief 6 || extension of time, through May 15, 2023, to complete the outstanding term of the settlement and to 7 || file dispositional documentation in this matter. 8 It is so stipulated. 9 10 Dated: April 20, 2023 THE BARRY LAW FIRM By:_ Fz 12 David N. Barry Anna H. Galaviz 13 Attorneys for Plaintiff, 4 GILBERTO PEREZ 15 Dated: April 20, 2023 LEWIS BRISBOIS BISGAARD & SMITH 16 LLP 17 18 By: ft H. atis 19 Attorney for Defendant, 20 FORD MOTOR COMPANY 21 22 23 24 25 26 27 28 STIPULATION FOR EXTENSION OF TIME TO FILE DISPOSITIONAL DOCUMENTS: 1 2 Pursuant to Local Rule 160(b), the Court may extend the time for filing dispositional papers 3 for good cause shown. See Sprague v. Fin. Credit Network, Inc., 2018 WL 4616688, at *4 (E.D. 4 Cal. Sept. 25, 2018) (“[Good cause] requires the party to show that despite due diligence the 5 scheduled deadline could not be met.”). Based upon the Parties’ efforts to complete their 6 settlement terms and the Parties’ Stipulation to the amended deadline, the Court finds that the 7 Parties’ request is warranted. 8 Accordingly, IT IS HEREBY ORDERED that the Parties shall file appropriate papers to 9 dismiss this action in its entirety no later than May 15, 2023. 10 IT IS SO ORDERED. 11 12 13 Dated: April 20, 2023 /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA 14 UNITED STATES DISTRICT JUDGE 15 16 17 18 19 20 21 22 23 24 25 26 27 28