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QUILL & ARROW, LLP
Kevin Y. Jacobson (SBN 320532)
Kiacobson@quillarrowlaw.com s
“PERU? FI
David Derderian (SBN 349787) csfigmaoulérfib
dderderian@quillarrowlaw.com 95‘?an BEWORN“
e-service@quillarrowlaw.com
10900 Wilshire Boulevard, Suite 300 J4N
25
Los Angeles, CA 90024 2024
5,,
Telephone: (3 10) 933-4271 ,
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Facsimile: (3 10) 889-0645 JESS
Attorneys for Plaintiff, Jo
4M9,
RHONDA MCDOWELL DEPUTY
WILSON TURNER KOSMO LLP
ELIZABETH C. REIN (297593)
ANDRES F. MICHEL (292626)
402 West Broadway, Suite 1600
San Diego, California 92101
Telephone: (619) 236-9600
FaCSImile: (619) 236-9669
E-mail: erein@wilsonturnerkosmo.com
E-mail: amichel@wilsontumerkosmo.com
E-mail: hondaeservice@wilsontumerkosmo.com
Attorney for Defendant,
AMERICAN HONDA MOTOR CO., INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO JUSTICE CENTER
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RHONDA MCDOWELL, an individual, Case NO-I CIVSBZZI 1661
Assigned to the Honorable Brian S. McCarville
in Department S30
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Plaintiff,
STIPULATION TO CONTINUE HEARING
vs_ DATE OF PLAINTIFF’S MOTION T0
COMPEL FURTHER RESPONSES TO
PLAINTIFF’S REQUESTS FOR
PRODUCTION 0F DOCUMENTS, SET
AMERICAN HONDA MOTOR CO., INC, a TWO; [PROPOSED] ORDER
California Corporation, and DOES 1 through $70.“
10, inclusive, . .
sumu'omqq
Complalnt Flled: June 9, 2022
Hearm Date: February 1,2024
Time: 8:30 AM. F ¥
Defendant. ‘
..
”2-
«
-1-
STIPULATION TO CONTINUE MOTION TO COMPEL; [PROPOSED] ORDER
_ IT IS HEREBY STIPULATED and agreed upon, by and between Plaintiff, RHONDA
MCDOWELL (“Plaintiff"), and Defendant AMERICAN HONDA MOTOR C0,, INC. (“AHM”
or “Defendant") (the parties shall collectively be referred to herein as the “Parties”), by and through
their respective counsel of record, that the currently-scheduled: Plaintiff’s Motion to Compel
Further Responses to Plaintiff‘s Requests for Production of Documents, Set Two, hearing date set
©00\l0\MAUJN
for February 1, 2024, be continued to thirty (30) days, March 4, 2024, or as soon thereafter as the
Court is available. The Parties stipulate to the requested continuances on the following grounds:
1. Plaintiff‘s Motion to Compel Further Responses to Plaintiff‘s Requests for
Production of Documents, Set Two, is currenty scheduled for February 1, 2024.
Despite the timely filing of Plaintiff’s Motion to Compel Further Responses to
Plaintiff’s Requests for Production ofDocuments, Set Two, on November 17, 2023,
the Motion documents were not electronically served to Defendant’s counsel.
Due to inadvertence and excusable neglect in Plaintiff’s failure to properly serve
the moving papers, the counsel for both Parties stipulate for the Court’s availability
for a new Motion to Compel date.
The counsel for both Parties have met and conferred as to this stipulation and their
availability for a new Motion to Compel date. (Cal. Rules of Court, rule 3.1332,
subd. (d)(8).) All parties agree to the instant request.
WNQMAWN—‘OOWNQMAU’N—‘O
NNNNNNNNN—Hr—Hp—H——.——
Due to the foregoing, good cause exists for the requested continuance of Plaintiff‘s
Motion to Compel Further Responses to Plaintiff’s Requests for Production of
Documents, Set Two, to allow the Parties to properly continue communication
regarding resolution ofthis matter and to allow sufficient notice. The Parties submit
that the requested continuance will not prejudice any party, rather, will further the
interests ofjustice in this matter.
Based on the foregoing recitals. Plaintiff and Defendant, through their respective counsel
stipulate as follows:
1. That Plaintiff’s Motion to Compel Further Responses to Production of Documents,
Set Two, currently scheduled for February l, 2024, be continued to thirty (30) days,
-2.
STIPULATION TO CONTINUE MOTION TO COMPEL; [PROPOSED] ORDER
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QUILL & ARROW, LLP Kevin Y. Jacobson (SBN 320532) Kiacobson@quillarrowlaw.com s “PERU? FI David Derderian (SBN 349787) csfigmaoulérfib dderderian@quillarrowlaw.com 95‘?an BEWORN“ e-service@quillarrowlaw.com 10900 Wilshire Boulevard, Suite 300 J4N 25 Los Angeles, CA 90024 2024 5,, Telephone: (3 10) 933-4271 , \OOO\IO\MAUJNp—n Facsimile: (3 10) 889-0645 JESS Attorneys for Plaintiff, Jo 4M9, RHONDA MCDOWELL DEPUTY WILSON TURNER KOSMO LLP ELIZABETH C. REIN (297593) ANDRES F. MICHEL (292626) 402 West Broadway, Suite 1600 San Diego, California 92101 Telephone: (619) 236-9600 FaCSImile: (619) 236-9669 E-mail: erein@wilsonturnerkosmo.com E-mail: amichel@wilsontumerkosmo.com E-mail: hondaeservice@wilsontumerkosmo.com Attorney for Defendant, AMERICAN HONDA MOTOR CO., INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO SAN BERNARDINO JUSTICE CENTER NNNNNNNNNpr—au—au—u—nr—wr—— RHONDA MCDOWELL, an individual, Case NO-I CIVSBZZI 1661 Assigned to the Honorable Brian S. McCarville in Department S30 WNQMAWNF‘OCWQOMAWNHO Plaintiff, STIPULATION TO CONTINUE HEARING vs_ DATE OF PLAINTIFF’S MOTION T0 COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQUESTS FOR PRODUCTION 0F DOCUMENTS, SET AMERICAN HONDA MOTOR CO., INC, a TWO; [PROPOSED] ORDER California Corporation, and DOES 1 through $70.“ 10, inclusive, . . sumu'omqq Complalnt Flled: June 9, 2022 Hearm Date: February 1,2024 Time: 8:30 AM. F ¥ Defendant. ‘ .. ”2- « -1- STIPULATION TO CONTINUE MOTION TO COMPEL; [PROPOSED] ORDER _ IT IS HEREBY STIPULATED and agreed upon, by and between Plaintiff, RHONDA MCDOWELL (“Plaintiff"), and Defendant AMERICAN HONDA MOTOR C0,, INC. (“AHM” or “Defendant") (the parties shall collectively be referred to herein as the “Parties”), by and through their respective counsel of record, that the currently-scheduled: Plaintiff’s Motion to Compel Further Responses to Plaintiff‘s Requests for Production of Documents, Set Two, hearing date set ©00\l0\MAUJN for February 1, 2024, be continued to thirty (30) days, March 4, 2024, or as soon thereafter as the Court is available. The Parties stipulate to the requested continuances on the following grounds: 1. Plaintiff‘s Motion to Compel Further Responses to Plaintiff‘s Requests for Production of Documents, Set Two, is currenty scheduled for February 1, 2024. Despite the timely filing of Plaintiff’s Motion to Compel Further Responses to Plaintiff’s Requests for Production ofDocuments, Set Two, on November 17, 2023, the Motion documents were not electronically served to Defendant’s counsel. Due to inadvertence and excusable neglect in Plaintiff’s failure to properly serve the moving papers, the counsel for both Parties stipulate for the Court’s availability for a new Motion to Compel date. The counsel for both Parties have met and conferred as to this stipulation and their availability for a new Motion to Compel date. (Cal. Rules of Court, rule 3.1332, subd. (d)(8).) All parties agree to the instant request. WNQMAWN—‘OOWNQMAU’N—‘O NNNNNNNNN—Hr—Hp—H——.—— Due to the foregoing, good cause exists for the requested continuance of Plaintiff‘s Motion to Compel Further Responses to Plaintiff’s Requests for Production of Documents, Set Two, to allow the Parties to properly continue communication regarding resolution ofthis matter and to allow sufficient notice. The Parties submit that the requested continuance will not prejudice any party, rather, will further the interests ofjustice in this matter. Based on the foregoing recitals. Plaintiff and Defendant, through their respective counsel stipulate as follows: 1. That Plaintiff’s Motion to Compel Further Responses to Production of Documents, Set Two, currently scheduled for February l, 2024, be continued to thirty (30) days, -2. STIPULATION TO CONTINUE MOTION TO COMPEL; [PROPOSED] ORDER