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MARTIN F. JENNINGS, Jr. SBN 040876 

STEPHAN A. MANDELL SBN 095461 

P.O.Box 2239 

Granite Bay, CA 95746 

Telephone: (916) 791-2374 

Fax: (916) 791-3195 

Attorneys for Plaintiff 

DENISE YEAGER 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

DENISE YEAGER, 

 Plaintiffs, 

vs. 

AUBURN HONDA, JAY COOPER, JIMMY RAY 

MULLINS; AMERICAN HONDA MOTOR CO., 

INC., and DOES 1 through 30, inclusive, 

 Defendants. 

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Case No.: CIV S-04-0912 WBS GGH 

STIPULATION OF THE PARTIES TO EXTEND 

THE CUT-OFF DATE FOR MOTIONS FROM 

3/30/06 to 4/28/06 AND TO CONTINUE 

DEFENDANTS' SUMMARY JUDGMENT 

MOTION FROM 2/24/06 TO 4/17/06. 

IT IS HEREBY STIPULATED by and between the parties that good cause exists to extend the 

present cut-off date for motions from 3/30/06 to 4/28/06 and to continue Defendants' Motion for Summary 

Judgment currently set for 3/30/06 to 4/17/06. 

The parties also agree to waive the discovery deadline of January 31, 2006 with reference to the 

currently scheduled depositions of DeeAnna Keck and "The Person Most Knowledgeable". Said depositions 

are currently set for January 26th and January 27th, 2006. 

Good cause herein consists of the following: 

1. Plaintiff's counsel of record MARTIN F. JENNINGS, Jr. has scheduled the deposition of 

Defendant AUBURN HONDA corporate officer DEEANNA KECK and the Person Most Knowledgeable on 

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January 26 and 27th, 2006 respectively. Defendants' counsels have indicated a conflict with these dates 

especially in light of the parties preparation for mediation scheduled for February 1 and 2, 2006. 

2. The scheduled depositions are necessary for Plaintiff's opposition to the currently set Motion 

for Summary Judgment and the parties agree to continue these depositions provided that the Motion for 

Summary Judgment is continued until April 17, 2006. 

3. Plaintiff's counsel MARTIN F. JENNINGS, Jr. has a paid, non-refundable vacation scheduled 

in Mexico which begins on February 15, 2006 and ends on March 18, 2006. This vacation has been booked 

since March 2005. Plaintiff's co-counsel STEPHAN MANDELL continues to be treated for serious injuries 

he suffered in February 2003 when his car was struck by a school bus. Mr. MANDELL is unavailable to 

assist in these matters, having had 4 surgeries in the last 18 months, plus 4 surgical procedures at UCLA 

during that time. Mr. MANDELL has not been able to return to even a consistent part-time schedule, and has 

now learned that his surgically repaired bones have become deformed, occasioning further surgery. 

4. Extending the Motions deadline and continuing the Motion for Summary Judgment will not 

affect any other case timelines, including the present trial date. 

IT IS SO STIPULATED: 

 Dated: 1/20/06 /S/ 

 

 Martin F. Jennings, Jr. 

 Attorney for Plaintiff 

 Dated: 1/22/06 /S/ 

 

 John Britton 

 WRIGHT and BRITTON 

 Attorney for Defendants Auburn Honda 

 and Jay Cooper 

 

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 Dated: 1/23/06 

 

 /S/ 

 

 Daniel Costa 

 Attorney for Defendant Jim Mullins 

GOOD CAUSE APPEARING HEREIN, the discovery cut-off date for the two depositions 

referenced above is extended to March 30, 2006. The cut-off date for Motions is extended from February 24, 

2006 to April 28, 2006. Defendants' Motion for Summary Judgment is continued to April 17, 2006. 

Dated: January 25, 2006 

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