Preview
V v‘
'
ORDINAL
DYKEMA GOSSETT LLP
ABIRAMI GNANADESIGAN, SBN 263375
AGnanadesigan@dykema.com i L E D
SUPERIOR COURT 0F CALIFORNIA
333 South Grand Avenue, Suite 2100
COUNTY 0F SAN BERNARDiNo
Los Angeles, California 90071 SAN BERNARDINQ ms-rRICT
Telephone: (213) 457-1800
Facsimne: (213)457-1850
HARLEY-
Attorneys for Cross-Defendant,
DAVIDSON MOTOR COMPANY, INC.
BY mxJUL 3 0 2021
R FAEL HERNANDEZDEPUTY
FAX
SUPERIOR COURT 0F THE STATE OF CALIFORNIA
BY COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
10
11 LISA HILL, an individual Case No. CIVSD1826573
90071
LLP
12 Plaintiff, Assigned t0 Hon. Wilfred J. Schneider, Jr.
AVENUE
Dept. S32
CALIFORNIA
13 v.
100
GOSSETT
GRAND 2
SUITE
14 QUAID HARLEY-DAVIDSON, INC., a
California Corporation, and DOES through 1 JOINT STIPULATION EXTENDING
SOUTH
ANGELES,
15 10, inclusive, CROSS-DEFENDANT’S TIME TO
DYKEMA
RESPOND TO CROSS-COMPLAINT;
333
Los
16 Defendant. [FWD] ORDER
17
18 QUAID HARLEY-DAVIDSON, INC., a
California Corporation,
19
Cross—Complainant,
20
21 v.
22 HARLEY-DAVIDSON MOTOR
COMPANY, INC., a Wisconsin corporation,
23 and ROES through 10, inclusive,
1
24
Cross-Defendants.
25
26
27
28
002450342 1
JOINT STIPULATION EXTENDING CROSS-DEFENDANT’S TIME TO RESPOND TO CROSS-COMPLAINT; [mm ORDER
Pursuant to Rule 3.1 10(6) of the California Rules of Court, Cross-Complainant Quaid
Harley-Davidson, Inc. (“Cross-Complainant”) and Cross-Defendant Harley-Davidson Motor
Company, Inc. (“Cross-Defendant”) (collectively, the “Parties”), by and through their respective
counsel, hereby stipulate and agree as follows:
WHEREAS, Cross—Complainant filed its Cross—Complaint against Cross-Defendant on 0r
about May 28, 2021, which was served on Cross-Defendant on 0r about June 10, 2021;
WHEREAS, Cross-Defendant’s initial deadline to respond to the Cross-Complaint was
July 12, 2021;
WHEREAS, in an attempt to narrow the claims at issue, the Parties stipulated to an
10 extension 0f time for Cross-Defendant t0 respond t0 the Cross—Complaint up to and including July
11 26, 2021;
90071
LLP
12 WHEREAS, on July 8, 2021, the Parties met and conferred telephonically about Cross-
AVENUE
CALIFORNIA
13 Defendant’s anticipated demurrer to the Cross-Complaint and exchanged follow-up
GOSSETT 2100
GRAND
14 correspondence on July 19, July 21, and July 25, 2021;
SUITE
SOUTH
ANGELES,
15 WHEREAS, 0n July 26, 2021, as a result of the Parties’ meet and confer efforts, Cross-
DYKEMA
333
Los
16 Complainant agreed to amend certain causes 0f action contained in the Cross—Complaint;
17 WHEREAS, the Parties agree that there is no need for Cross-Defendant to file a response
18 to the Cross—Complaint given Cross-Complainant’s intention to file a First Amended Cross-
19 Complaint;
20 WHEREAS, the Parties stipulate t0 a seven day extension of time for Cross—Defendant to
21 file a response to the Cross-Complaint, if any, up to and including August 2, 2021, and request
22 that this Court enter an Order on such Stipulation;
23 IT IS SO STIPULATED.
24 Dated: July ELZOZI DYKEMA GOSSETT LLP
25
26
Abirami Gnanadesigan
27
Attorneys for Cross—Defendant
28
HARLEY-DAVIDSON MOTOR
COMPANY, INC.
002450342 2
JOINT STIPULATION EXTENDING CROSS-DEFENDANT’S TIME TO RESPOND TO CROSS-COMPLAINT; [EROBGSE-B} ORDER
Preview
V v‘ ' ORDINAL DYKEMA GOSSETT LLP ABIRAMI GNANADESIGAN, SBN 263375 AGnanadesigan@dykema.com i L E D SUPERIOR COURT 0F CALIFORNIA 333 South Grand Avenue, Suite 2100 COUNTY 0F SAN BERNARDiNo Los Angeles, California 90071 SAN BERNARDINQ ms-rRICT Telephone: (213) 457-1800 Facsimne: (213)457-1850 HARLEY- Attorneys for Cross-Defendant, DAVIDSON MOTOR COMPANY, INC. BY mxJUL 3 0 2021 R FAEL HERNANDEZDEPUTY FAX SUPERIOR COURT 0F THE STATE OF CALIFORNIA BY COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT 10 11 LISA HILL, an individual Case No. CIVSD1826573 90071 LLP 12 Plaintiff, Assigned t0 Hon. Wilfred J. Schneider, Jr. AVENUE Dept. S32 CALIFORNIA 13 v. 100 GOSSETT GRAND 2 SUITE 14 QUAID HARLEY-DAVIDSON, INC., a California Corporation, and DOES through 1 JOINT STIPULATION EXTENDING SOUTH ANGELES, 15 10, inclusive, CROSS-DEFENDANT’S TIME TO DYKEMA RESPOND TO CROSS-COMPLAINT; 333 Los 16 Defendant. [FWD] ORDER 17 18 QUAID HARLEY-DAVIDSON, INC., a California Corporation, 19 Cross—Complainant, 20 21 v. 22 HARLEY-DAVIDSON MOTOR COMPANY, INC., a Wisconsin corporation, 23 and ROES through 10, inclusive, 1 24 Cross-Defendants. 25 26 27 28 002450342 1 JOINT STIPULATION EXTENDING CROSS-DEFENDANT’S TIME TO RESPOND TO CROSS-COMPLAINT; [mm ORDER Pursuant to Rule 3.1 10(6) of the California Rules of Court, Cross-Complainant Quaid Harley-Davidson, Inc. (“Cross-Complainant”) and Cross-Defendant Harley-Davidson Motor Company, Inc. (“Cross-Defendant”) (collectively, the “Parties”), by and through their respective counsel, hereby stipulate and agree as follows: WHEREAS, Cross—Complainant filed its Cross—Complaint against Cross-Defendant on 0r about May 28, 2021, which was served on Cross-Defendant on 0r about June 10, 2021; WHEREAS, Cross-Defendant’s initial deadline to respond to the Cross-Complaint was July 12, 2021; WHEREAS, in an attempt to narrow the claims at issue, the Parties stipulated to an 10 extension 0f time for Cross-Defendant t0 respond t0 the Cross—Complaint up to and including July 11 26, 2021; 90071 LLP 12 WHEREAS, on July 8, 2021, the Parties met and conferred telephonically about Cross- AVENUE CALIFORNIA 13 Defendant’s anticipated demurrer to the Cross-Complaint and exchanged follow-up GOSSETT 2100 GRAND 14 correspondence on July 19, July 21, and July 25, 2021; SUITE SOUTH ANGELES, 15 WHEREAS, 0n July 26, 2021, as a result of the Parties’ meet and confer efforts, Cross- DYKEMA 333 Los 16 Complainant agreed to amend certain causes 0f action contained in the Cross—Complaint; 17 WHEREAS, the Parties agree that there is no need for Cross-Defendant to file a response 18 to the Cross—Complaint given Cross-Complainant’s intention to file a First Amended Cross- 19 Complaint; 20 WHEREAS, the Parties stipulate t0 a seven day extension of time for Cross—Defendant to 21 file a response to the Cross-Complaint, if any, up to and including August 2, 2021, and request 22 that this Court enter an Order on such Stipulation; 23 IT IS SO STIPULATED. 24 Dated: July ELZOZI DYKEMA GOSSETT LLP 25 26 Abirami Gnanadesigan 27 Attorneys for Cross—Defendant 28 HARLEY-DAVIDSON MOTOR COMPANY, INC. 002450342 2 JOINT STIPULATION EXTENDING CROSS-DEFENDANT’S TIME TO RESPOND TO CROSS-COMPLAINT; [EROBGSE-B} ORDER