Alvarado v. Darin M. Camarena Health Centers, Inc.

Filing 42

STIPULATION and ORDER extending scheduling dates. Third party defendants' disclosure of expert witnesses due 3/6/2009. Plaintiff and United States disclosure of supplemental expert witnesses due 4/3/2009. Cutoff for non-expert discovery 4/17/ 2009. Discovery due by 6/26/2009. Non-Dispositive Motions due by 7/24/2009. Dispositive Motion due by 9/11/2009. Pretrial Conference currently set for 10/26/2009 is continued to 11/9/2009 at 11:00 AM in Courtroom 3 (OWW) before Judge Oliver W. Wanger. Order signed by Judge Oliver W. Wanger on 1/30/2009. (Timken, A)

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LAWRENCE G. BROWN Acting United States Attorney JEFFREY J. LODGE Assistant United States Attorney United States Courthouse 2500 Tulare Street, Suite 4401 Fresno, California 93721 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant/Third-Party Plaintiff United States of America UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA LORENA S. ALVARADO, a minor, by and through her Guardian ad Litem LORENA ALVARADO, ) ) ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) ) ) UNITED STATES OF AMERICA, ) ) Third-Party Plaintiff, ) ) v. ) ) CHILDREN'S HOSPITAL CENTRAL ) CALIFORNIA, JOHN E. DINSMORE, ) MD, DAVID HODGE, MD, and JILL ) GHANBARIAN, FNP, ) ) Third-Party Defendants. ) ) 1:06-cv-01381-OWW-DLB STIPULATION RE SCHEDULING DATES; ORDER

The parties hereby stipulate, by and through their respective counsel, to revise the discovery deadline, expert disclosure dates, and other related deadlines. A short extension

of the deadlines is necessary to accommodate the schedules of the /// 1
STIPULATION RE SCHEDULING DATES; [PROPOSED] ORDER

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witnesses and counsel. action's trial date.

The parties do not seek to continue this

The parties base this stipulation on good cause.

Many of

the witnesses are medical professionals with limited ability to be available for discovery. relocated to Virginia. One of the treating physicians has

A short extension of the expert

disclosure deadlines, discovery, and motion cutoffs is necessary to accommodate the schedules of the witnesses and counsel. Based on the above, the parties hereby stipulate to extend the following deadlines: Old Date Third party Defendants' disclose expert witnesses: Plaintiff and United States disclose supplemental expert witnesses: Cutoff for non-expert discovery: Cutoff for expert discovery: Last day to file non-dispositive motions: Last day to file dispositive motions: Pre-trial conference: February 6, 2009 New Date March 6, 2009

March 6, 2009 March 6, 2009 June 5, 2009 June 19, 2009 August 7, 2009 October 26, 2009

April 3, 2009 April 17, 2009 June 26, 2009 July 24, 2009 September 11, 2009 November 9, 2009

Motions shall be set on the first available date after the filing cutoff, allowing for timely service. All other deadlines set

forth in the Scheduling Conference Order filed September 22, 2008, shall remain in effect unless otherwise approved by the

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STIPULATION RE SCHEDULING DATES; [PROPOSED] ORDER

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Court.

The parties request the Court to endorse this stipulation

by way of formal order. Respectfully submitted, Dated: January 30, 2009. GWILLIAM, IVARY, CHIOSSO, CAVALLI & BREWER /s/ Steven J. Brewer (auth. By: Steven J. Brewer Attorneys for Plaintiff Dated: January 30, 2009.
1-30-09)

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MCNAMARA, DODGE, NEY, BEATTY, SLATTERY, PFALZER, BORGES & BROTHERS, LLP /s/ Robert W. Hodges (auth. 1-30-09) By: Robert W. Hodges Attorneys for Third-Party Defendant, David Hodge, MD STAMMER, MCKNIGHT, BARNUM & BAILEY, LLP /s/ Jerry D. Jones (auth. 1-30-09) By: Jerry D. Jones Attorneys for Third-Party Defendants, Children's Hospital Central California and Jill Ghanbarian, FNP MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH, LLP /s/ Lawrence E. Wayte (auth. 1-30-09) By: Lawrence E. Wayte Attorneys for Third-Party Defendant, John E. Dinsmore, MD

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STIPULATION RE SCHEDULING DATES; [PROPOSED] ORDER

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Dated: January 29, 2009.

LAWRENCE G. BROWN Acting United States Attorney By: /s/ Jeffrey J. Lodge JEFFREY J. LODGE Assistant U.S. Attorney Attorneys for Federal CrossDefendants United States of America and United States Postal Service

ORDER 9 IT IS SO ORDERED. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4
STIPULATION RE SCHEDULING DATES; [PROPOSED] ORDER

Dated: January 30, 2009 emm0d6

/s/ Oliver W. Wanger UNITED STATES DISTRICT JUDGE