arrow left
arrow right
  • Ross VS Bayerische Motoren Werke AG Unlimited Civil (Product Liability (not asbest...) document preview
  • Ross VS Bayerische Motoren Werke AG Unlimited Civil (Product Liability (not asbest...) document preview
  • Ross VS Bayerische Motoren Werke AG Unlimited Civil (Product Liability (not asbest...) document preview
  • Ross VS Bayerische Motoren Werke AG Unlimited Civil (Product Liability (not asbest...) document preview
  • Ross VS Bayerische Motoren Werke AG Unlimited Civil (Product Liability (not asbest...) document preview
  • Ross VS Bayerische Motoren Werke AG Unlimited Civil (Product Liability (not asbest...) document preview
  • Ross VS Bayerische Motoren Werke AG Unlimited Civil (Product Liability (not asbest...) document preview
  • Ross VS Bayerische Motoren Werke AG Unlimited Civil (Product Liability (not asbest...) document preview
						
                                

Preview

|MA A 222022 Michele Ballard Miller (SBN 104198) = mbmiller@cozen.com Elena K. Hillman (SBN 157337) . PDO ehillman@cozen.com FILED COZEN O'CONNOR WO 101 Montgomery Street, Suite 1400 ALAMEDA COUNTY San Francisco, CA 9410 Jui: om FB Telephone: Cr Ns 4 1013 0 2021 Facsimile: (415) 644- CLERK OF THE SUPERIOR COURT oO for Defendant ew ae, Ae Lea Attorneys OO THE PERMANENTE MEDICAL GROUP, INC. Nn Oo SUPERIOR COURT OF THE STATE OF CALIFORNIA oOo COUNTY OF ALAMEDA - ee O SO | DONNA MCCLANE, Case No.: RG19014777 er NH Plaintiff, ASSIGNED FOR ALL PURPOSES TO ST, Sure 1400 JUDGE Stephen Pulido SAN FRANcIsSco, CA 94104 WH ee O'CONNOR V. DEPARTMENT 517 KR er 101 MonTGomEeRY THE PERMANENTE MEDICAL GROUP, JOINT STIPULATION TO CONTINUE COZEN INC. a California corporation, d/;b/a Kaiser | TRIAL DATE AND ALL RELATED FN eo Permanente; and DOES 1-50, inclusive, PRETRIAL DATES AND REQUEST FOR A TRIAL SETTING CONFERENCE AND DO = Defendant. [PREFOSED] ORDER - AZ-vV/ LEWITTER MALKANI 101 Monroomery Sr, SuiTe 1400 Gx |b [o> CA 94104 oe O'CONNOR SAN FRANCISCO, ok CozeNn oaWeber we Attorneys forPlaintiff DONNA MCCLANE ee -Dated: June 21, 2021 COZEN O'CONNOR wd Tins. Konda, Yl By: wd Elena Hillman Attorneys for Defendant DR THE PERMANENTE MEDICAL GROUP, INC. PA DN PO DN PO PR PR NM 4 JOINT STIPULATION TO CONTINUE TRIAL DATE AND ALL RELATED PRETRIAL DATES AND REQUEST FOR TRIAL SETTING CONFERENCE; [PROPOSED] ORDER - Case No: RG19014777 11. Accordingly, to prevent prejudice to either Party, and to facilitate = further settlement efforts, the Parties STIPULATE and AGREE to vacate the trialdate of DB November 15, 2021, along with all pre-trial deadlines, including, but not limited to, W deadlines for the completion of discovery and the date for dispositive motions, and continue BF the trial date. Therefore, the Parties request that the Court schedule a trial setting oO conference to be set at such date and time as may be convenient for the Court. Defendant DO will not file a. Motion for Summary Judgement and/or Summary Adjudication until that time. nN Defendant may request a later hearing for a dispositive motion after the Court sets a new OA trialdate. oO tk Respectfully submitted, Dated: June 21, 2021 —> LEWITTER MALKANI 101 Monroomery Sr, SuiTe 1400 Gx |b [o> CA 94104 oe O'CONNOR SAN FRANCISCO, ok CozeNn oaWeber we Attorneys forPlaintiff DONNA MCCLANE ee -Dated: June 21, 2021 COZEN O'CONNOR wd Tins. Konda, Yl By: wd Elena Hillman Attorneys for Defendant DR THE PERMANENTE MEDICAL GROUP, INC. PA DN PO DN PO PR PR NM 4 JOINT STIPULATION TO CONTINUE TRIAL DATE AND ALL RELATED PRETRIAL DATES AND REQUEST FOR TRIAL SETTING CONFERENCE; [PROPOSED] ORDER - Case No: RG19014777 11. Accordingly, to prevent prejudice to either Party, and to facilitate = further settlement efforts, the Parties STIPULATE and AGREE to vacate the trialdate of DB November 15, 2021, along with all pre-trial deadlines, including, but not limited to, W deadlines for the completion of discovery and the date for dispositive motions, and continue BF the trial date. Therefore, the Parties request that the Court schedule a trial setting oO conference to be set at such date and time as may be convenient for the Court. Defendant DO will not file a. Motion for Summary Judgement and/or Summary Adjudication until that time. nN Defendant may request a later hearing for a dispositive motion after the Court sets a new OA trialdate. oO tk Respectfully submitted, Dated: June 21, 2021 —> LEWITTER MALKANI 101 Monroomery Sr, SuiTe 1400 Gx |b [o> CA 94104 oe O'CONNOR SAN FRANCISCO, ok CozeNn oaWeber we Attorneys forPlaintiff DONNA MCCLANE ee -Dated: June 21, 2021 COZEN O'CONNOR wd Tins. Konda, Yl By: wd Elena Hillman Attorneys for Defendant DR THE PERMANENTE MEDICAL GROUP, INC. PA DN PO DN PO PR PR NM 4 JOINT STIPULATION TO CONTINUE TRIAL DATE AND ALL RELATED PRETRIAL DATES AND REQUEST FOR TRIAL SETTING CONFERENCE; [PROPOSED] ORDER - Case No: RG19014777 11. Accordingly, to prevent prejudice to either Party, and to facilitate = further settlement efforts, the Parties STIPULATE and AGREE to vacate the trialdate of DB November 15, 2021, along with all pre-trial deadlines, including, but not limited to, W deadlines for the completion of discovery and the date for dispositive motions, and continue BF the trial date. Therefore, the Parties request that the Court schedule a trial setting oO conference to be set at such date and time as may be convenient for the Court. Defendant DO will not file a. Motion for Summary Judgement and/or Summary Adjudication until that time. nN Defendant may request a later hearing for a dispositive motion after the Court sets a new OA trialdate. oO tk Respectfully submitted, Dated: June 21, 2021 —> LEWITTER MALKANI 101 Monroomery Sr, SuiTe 1400 Gx |b [o> CA 94104 oe O'CONNOR SAN FRANCISCO, ok CozeNn oaWeber we Attorneys forPlaintiff DONNA MCCLANE ee -Dated: June 21, 2021 COZEN O'CONNOR wd Tins. Konda, Yl By: wd Elena Hillman Attorneys for Defendant DR THE PERMANENTE MEDICAL GROUP, INC. PA DN PO DN PO PR PR NM 4 JOINT STIPULATION TO CONTINUE TRIAL DATE AND ALL RELATED PRETRIAL DATES AND REQUEST FOR TRIAL SETTING CONFERENCE; [PROPOSED] ORDER - Case No: RG19014777 = PH WH cause therefore, the Joint Stipulation is BR IT IS ORDERED as follows; A oO 1. The trial date of Nove er 15, 2021 is vacated and the trial is continued to OD ,2022. N 2. All deadlines refated to the trial date, including, but not limited to, all discovery Oa deadlines and the deadine for the Court to hear motions for summary judgment, will be O© calculated based on Ahe new trialdate. oO = 3. A thal setting conference is set for =| = NYO HS ITISSOORDERED. ~— A evi dD HS WO FSF KR Dated: G. 24-292) CN _] OTD FSF Hon. Stephen Pukdo~\, OO FB Nn FS DB FS FA O |FO HMO PNM | NOD NM WO KR BR RN oO BN OO BR VN DRO Oo N 5 JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED DEADLINES; AND [PROPOSED] ORDER THEREON - Case No: RG19014777 = PH WH cause therefore, the Joint Stipulation is BR IT IS ORDERED as follows; A oO 1. The trial date of Nove er 15, 2021 is vacated and the trial is continued to OD ,2022. N 2. All deadlines refated to the trial date, including, but not limited to, all discovery Oa deadlines and the deadine for the Court to hear motions for summary judgment, will be O© calculated based on Ahe new trialdate. oO = 3. A thal setting conference is set for =| = NYO HS ITISSOORDERED. ~— A evi dD HS WO FSF KR Dated: G. 24-292) CN _] OTD FSF Hon. Stephen Pukdo~\, OO FB Nn FS DB FS FA O |FO HMO PNM | NOD NM WO KR BR RN oO BN OO BR VN DRO Oo N 5 JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED DEADLINES; AND [PROPOSED] ORDER THEREON - Case No: RG19014777 = PH WH cause therefore, the Joint Stipulation is BR IT IS ORDERED as follows; A oO 1. The trial date of Nove er 15, 2021 is vacated and the trial is continued to OD ,2022. N 2. All deadlines refated to the trial date, including, but not limited to, all discovery Oa deadlines and the deadine for the Court to hear motions for summary judgment, will be O© calculated based on Ahe new trialdate. oO = 3. A thal setting conference is set for =| = NYO HS ITISSOORDERED. ~— A evi dD HS WO FSF KR Dated: G. 24-292) CN _] OTD FSF Hon. Stephen Pukdo~\, OO FB Nn FS DB FS FA O |FO HMO PNM | NOD NM WO KR BR RN oO BN OO BR VN DRO Oo N 5 JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED DEADLINES; AND [PROPOSED] ORDER THEREON - Case No: RG19014777 = PH WH cause therefore, the Joint Stipulation is BR IT IS ORDERED as follows; A oO 1. The trial date of Nove er 15, 2021 is vacated and the trial is continued to OD ,2022. N 2. All deadlines refated to the trial date, including, but not limited to, all discovery Oa deadlines and the deadine for the Court to hear motions for summary judgment, will be O© calculated based on Ahe new trialdate. oO = 3. A thal setting conference is set for =| = NYO HS ITISSOORDERED. ~— A evi dD HS WO FSF KR Dated: G. 24-292) CN _] OTD FSF Hon. Stephen Pukdo~\, OO FB Nn FS DB FS FA O |FO HMO PNM | NOD NM WO KR BR RN oO BN OO BR VN DRO Oo N 5 JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED DEADLINES; AND [PROPOSED] ORDER THEREON - Case No: RG19014777 Case Title: Ross v. Bayerische Motoren Werke Case No. RG20-084475 CLERK’S CERTIFICATE OF MAILING I certify that the following is true and correct: Iam a Deputy Clerk employed by the Alameda County Superior Court. I am over the age of 18 years. My business address is 24405 Amador Street, Hayward, California. I served the ORDER by placing copies in envelopes addressed as shown below and sealing and placing them for collection, stamping or metering with prepaid postage, and mailing on the date stated below, in the United States mail at Alameda County, California, following standard court practices. Miller, Michele Lanzetta, Tobin M. Cozen O'Coner Greene Broilet & Sheeler LLP 101 Montgomery Street Ste 1400 100 Wilshire Blvd. Ste 2100 San Francisco, CA 94104 Santa Monica, CA 90407-2131 Meyer, Steven E. Lewis Brisbois Bisgaard & Smith LLP 633 West 5" Street Ste. 4000 Los Angeles, CA 90071 Dated: 06-30-21 Chad Finke Executive Officer/Clerk of the Superior Court By: zZ HL Danielle Labrecgtte, Deputy Clerk | Revised 3/29/2016 Case Title: Ross v. Bayerische Motoren Werke Case No. RG20-084475 CLERK’S CERTIFICATE OF MAILING I certify that the following is true and correct: Iam a Deputy Clerk employed by the Alameda County Superior Court. I am over the age of 18 years. My business address is 24405 Amador Street, Hayward, California. I served the ORDER by placing copies in envelopes addressed as shown below and sealing and placing them for collection, stamping or metering with prepaid postage, and mailing on the date stated below, in the United States mail at Alameda County, California, following standard court practices. Miller, Michele Lanzetta, Tobin M. Cozen O'Coner Greene Broilet & Sheeler LLP 101 Montgomery Street Ste 1400 100 Wilshire Blvd. Ste 2100 San Francisco, CA 94104 Santa Monica, CA 90407-2131 Meyer, Steven E. Lewis Brisbois Bisgaard & Smith LLP 633 West 5" Street Ste. 4000 Los Angeles, CA 90071 Dated: 06-30-21 Chad Finke Executive Officer/Clerk of the Superior Court By: zZ HL Danielle Labrecgtte, Deputy Clerk | Revised 3/29/2016 Case Title: Ross v. Bayerische Motoren Werke Case No. RG20-084475 CLERK’S CERTIFICATE OF MAILING I certify that the following is true and correct: Iam a Deputy Clerk employed by the Alameda County Superior Court. I am over the age of 18 years. My business address is 24405 Amador Street, Hayward, California. I served the ORDER by placing copies in envelopes addressed as shown below and sealing and placing them for collection, stamping or metering with prepaid postage, and mailing on the date stated below, in the United States mail at Alameda County, California, following standard court practices. Miller, Michele Lanzetta, Tobin M. Cozen O'Coner Greene Broilet & Sheeler LLP 101 Montgomery Street Ste 1400 100 Wilshire Blvd. Ste 2100 San Francisco, CA 94104 Santa Monica, CA 90407-2131 Meyer, Steven E. Lewis Brisbois Bisgaard & Smith LLP 633 West 5" Street Ste. 4000 Los Angeles, CA 90071 Dated: 06-30-21 Chad Finke Executive Officer/Clerk of the Superior Court By: zZ HL Danielle Labrecgtte, Deputy Clerk | Revised 3/29/2016 Case Title: Ross v. Bayerische Motoren Werke Case No. RG20-084475 CLERK’S CERTIFICATE OF MAILING I certify that the following is true and correct: Iam a Deputy Clerk employed by the Alameda County Superior Court. I am over the age of 18 years. My business address is 24405 Amador Street, Hayward, California. I served the ORDER by placing copies in envelopes addressed as shown below and sealing and placing them for collection, stamping or metering with prepaid postage, and mailing on the date stated below, in the United States mail at Alameda County, California, following standard court practices. Miller, Michele Lanzetta, Tobin M. Cozen O'Coner Greene Broilet & Sheeler LLP 101 Montgomery Street Ste 1400 100 Wilshire Blvd. Ste 2100 San Francisco, CA 94104 Santa Monica, CA 90407-2131 Meyer, Steven E. Lewis Brisbois Bisgaard & Smith LLP 633 West 5" Street Ste. 4000 Los Angeles, CA 90071 Dated: 06-30-21 Chad Finke Executive Officer/Clerk of the Superior Court By: zZ HL Danielle Labrecgtte, Deputy Clerk | Revised 3/29/2016