IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

EASTERN DIVISION

DAVID FINNEY, an individual, )

)

Plaintiff, )

)

v. )

) CV. NO. 3:06-CV-622-WKW

)

NISSAN NORTH AMERICA, INC., )

a foreign corporation; TAKATA U.S.A. )

CORPORATION d/b/a TAKATA )

CORPORATION, a foreign corporation, )

Et al. )

)

Defendants. )

JOINT MOTION FOR EXTENSION OF 

DEADLINE TO FILE JOINT STIPULATION OF DISMISSAL

Now come Plaintiff and Defendants and request a ten-day extension to file a joint

stipulation of dismissal in this case. In support of this motion, the parties state as follows: 

1. The parties reached a settlement at mediation on January 29, 2008.

2. The Court subsequently issued an order giving the parties until February 19, 2008, 

to file a joint stipulation of dismissal. 

3. The parties filed a Joint Motion for Extension of Deadline to File Joint Stipulation 

of Dismissal on February 19, 2008, which the Court granted, extending the deadline until March 

4, 2008.

4. An additional extension until Friday, March 14 is requested to allow Defendants 

additional time to deliver the settlement proceeds to Plaintiffs. 

5. The undersigned represents that he has contacted counsel for each party in this 

case, that all parties join in this motion, and that counsel for each party has given him permission 

Case 3:06-cv-00622-WKW-SRW Document 70 Filed 03/04/2008 Page 1 of 3
to file this motion with the Court on behalf of all parties. 

WHEREFORE, the parties respectfully request a two-week extension of the deadline to 

file the joint stipulation of dismissal to allow them time to finalize the settlement release and to 

receive and deposit the settlement funds. 

Respectfully submitted this 4th day of March, 2008.

KING & SPALDING LLP

/s/ Andrew T. Bayman

Andrew T. Bayman (admitted pro hac vice)

Georgia Bar No. 043342

Robert B. Friedman (admitted pro hac vice)

Georgia Bar No. 277711

Robert C. Khayat, Jr.

Alabama Bar No. ASB-9156-T73R

1180 Peachtree Street 

Atlanta, Georgia 30309

Attorneys for Defendant

NISSAN NORTH AMERICA, INC.

Case 3:06-cv-00622-WKW-SRW Document 70 Filed 03/04/2008 Page 2 of 3
CERTIFICATE OF SERVICE

I certify that on March 4, 2008, I electronically filed this document with the Clerk of Court 

using the CM/ECF system, which will send notification of the filing to the following: 

Kenneth S Jackson

steve@jacksonandtucker.com

Joseph Luther Tucker 

josh@jacksonandtucker.com

Jackson and Tucker, P.C. 

2229 1st Avenue North 

Birmingham, AL 35203 

Walter B. Calton 

wcalton@bellsouth.net

Calton & Rutland LLC 

PO Box 696 

Eufaula, AL 36027-0696 

Charles Andrew Stewart, III

cstewart@bradleyarant.com

Angela R. Rogers

arogers@bradleyarant.com

Bradley Arant Rose & White, LLP

PO Box 1469 

Montgomery, AL 36102-1469

and I certify that I have mailed by United States Postal Service the document to the following nonCM/ECF participants: Not applicable. 

/s/ Andrew T. Bayman

Andrew T. Bayman (admitted pro hac vice)

Georgia Bar No. 043342

Robert B. Friedman (admitted pro hac vice)

Georgia Bar No. 277711

Robert C. Khayat, Jr.

Alabama Bar No. ASB-9156-T73R

1180 Peachtree Street 

Atlanta, Georgia 30309

Case 3:06-cv-00622-WKW-SRW Document 70 Filed 03/04/2008 Page 3 of 3