Perinatal Medical Group, Inc., et al. v. Children's Hospital Central CA, Inc.

Filing 93

STIPULATION and ORDER EXTENDING DISCOVERY DEADLINES signed by Magistrate Judge Michael J. Seng on 6/2/2011.(Disclosure of Expert Witnesses: 8/1/2011, Disclosure of Supplemental and/or Rebuttal Expert Witnesses: 8/29/2011, Non-Expert Discovery Deadline: 9/1/2011, Expert Discovery Deadline: 9/27/2011, Non-Dispositive Motion Deadline: 10/1/2011, Non-Dispositive Motion Hearing: On or before 11/4/2011.)(Yu, L)

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LAW OFFICES OF WILLIAM C. HAHESY
William C. Hahesy, Esq. – SBN 105743
225 West Shaw Avenue, Suite 105
Fresno, CA 93704
Tel: [phone]; Fax: [phone]
DAVIS WRIGHT TREMAINE LLP
Charles S. Wright, Esq. – SBN 31940
1201 Third Avenue, Suite 2200
Seattle, WA 98101-3045
Tel: [phone]; Fax: [phone]
Attorneys for Defendant, Children’s Hospital
Central California

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ATKINSON, ANDELSON, LOYA, RUUD & ROMO
William M. Woolman, Esq. - SBN 145124
5260 North Palm Avenue, Suite 300
Fresno, CA 93704
Tel: [phone]

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Attorneys for Defendant, Specialty Medical Group Central California

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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PERINATAL MEDICAL GROUP, INC.,
KRISHNAKUMAR RAJANI, M.D., and
STEPHEN ELLIOT, M.D.,
Plaintiffs,

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Civil Action No. 1:09-cv-1273-LJO-MJS
SECOND STIPULATION
EXTENDING DISCOVERY
DEADLINES

v.
CHILDREN’S HOSPITAL CENTRAL
CALIFORNIA, INC., a California corporation;
SPECIALTY MEDICAL GROUP CENTRAL
CALIFORNIA, INC., a California professional
medical corporation; and CENTRAL
CALIFORNIA NEONATOLOGY GROUP,
INC., a California professional medical
corporation,
Defendants.

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SECOND STIPULATION EXTENDING DISCOVERY DEADLINES

I. STIPULATION

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Plaintiffs PERINATAL MEDICAL GROUP, INC., KRISHNAKUMAR RAJANI, M.D.
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and STEPHEN ELLIOT, M.D. and Defendants CHILDREN’S HOSPITAL CENTRAL

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CALIFORNIA, SPECIALTY MEDICAL GROUP CENTRAL CALIFORNIA, INC., and
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CENTRAL CALIFORNIA NEONATOLOGY GROUP, INC., hereinafter collectively referred
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to as “the parties,” hereby stipulate to the following:

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1.

Discovery in this matter has been complex, involving numerous parties and third

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parties.
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2.

For several months the parties have been exchanging written discovery and

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working through their discovery disputes in good faith. However, despite the best efforts by the
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parties and counsel the production by all parties of documents, especially electronically stored
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information, has taken more time than expected.
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3.

As a result of mutual delays in document production, the parties had to postpone

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the start of depositions several months beyond what was originally anticipated. Moreover,
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despite the best efforts by the parties and counsel scheduling depositions has proven difficult
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given the professional schedules of various party and non-party witnesses, including numerous
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physicians. At least 15 depositions have been taken already. At least 24 depositions remain to
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be taken, not counting expert witnesses.
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4.

The parties believe a short extension of the pretrial discovery deadlines, and the

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related deadline for non-dispositive motions, would assist the just, speedy and inexpensive
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determination of this action. Besides permitting the parties to complete discovery in an orderly,
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efficient and complete manner, the short extension of approximately 30 days relative to most of
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the affected deadlines will enable the parties potentially to minimize or reduce additional
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expenses while the parties determine if they are able to or desire to proceed with potential
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settlement discussions.
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5.
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Therefore, the parties jointly stipulate to the following extensions of the discovery

deadlines set forth in the Court’s scheduling order dated June 29, 2010 [Dkt. 60], as previously

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SECOND STIPULATION EXTENDING DISCOVERY DEADLINES

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amended by this Court’s Order On Stipulation Extending Discovery Deadlines dated February

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11, 2011 [Dkt. 71]:

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EVENT
Disclosure of Expert Witnesses
Disclosure of Supplemental and/or
Rebuttal Expert Witnesses
Non-Expert Discovery Deadline
Expert Discovery Deadline
Non-Dispositive Motion Deadline

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6.

DEADLINE
August 1, 2011
August 29 2011
September 1, 2011
September 27, 2011
Filing: October 1, 2011
Hearing: On or before November 4, 2011

The parties are not requesting any other changes to the Court’s scheduling order.

Specifically, these changes will not affect the dispositive motion deadline or the trial date set

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forth in the scheduling order.
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IT IS SO STIPULATED:
Dated: May 26, 2011

LAW OFFICES OF WILLIAM C. HAHESY
By:

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Dated: May 26, 2011

s/ William C. Hahesy
William C. Hahesy
Attorneys for Defendant
CHILDREN’S HOSPITAL CENTRAL
CALIFORNIA

DAVIS WRIGHT TREMAINE LLP

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By:
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Dated: May 26, 2011

s/ Charles S. Wright
Charles S. Wright
Attorneys for Defendant
CHILDREN’S HOSPITAL CENTRAL
CALIFORNIA

ATKINSON, ANDELSON, LOYA, RUUD & ROMO

By:

s/ William M. Woolman
William M. Woolman
Attorneys for Defendant
SPECIALTY MEDICAL GROUP
CENTRAL CALIFORNIA, INC.

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SECOND STIPULATION EXTENDING DISCOVERY DEADLINES

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Dated: May 26, 2011

DOERKSEN TAYLOR LLP
By:

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Dated: May 26, 2011

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FISHMAN, LARSEN, GOLDRING & ZIETLER
By:

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Dated: May 26, 2011

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Dated: May 26, 2011

s/ Michael W. Goldring
Michael W. Goldring
Attorneys for Defendant
CENTRAL CALIFORNIA
NEONATOLOGY GROUP, INC.

CHRISTENSEN & AUER
By:

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s/ Charles L. Doerksen
Charles L. Doerksen
Attorneys for Defendant
CENTRAL CALIFORNIA
NEONATOLOGY GROUP, INC.

s/ Stephen G. Auer
Stephen G. Auer
Attorneys for Plaintiffs
PERINATAL MEDICAL GROUP, INC.,
KRISHNAKAMUR RAJANI, M.D., AND
STEPHEN ELLIOTT, M.D.

COLEMAN & HOROWITT, LLP
By:

s/ Darryl J. Horowitt
Darryl J. Horowitt
Attorneys for Plaintiffs
PERINATAL MEDICAL GROUP, INC.,
KRISHNAKAMUR RAJANI, M.D., AND
STEPHEN ELLIOTT, M.D.

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SECOND STIPULATION EXTENDING DISCOVERY DEADLINES

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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v.

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CHILDREN’S HOSPITAL CENTRAL
CALIFORNIA, INC., a California corporation;
SPECIALTY MEDICAL GROUP CENTRAL
CALIFORNIA, INC., a California professional
medical corporation; and CENTRAL
CALIFORNIA NEONATOLOGY GROUP,
INC., a California professional medical
corporation,
Defendants.
GOOD CAUSE HAVING BEEN SHOWN AND THE PARTIES HAVING

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ORDER ON SECOND
STIPULATION EXTENDING
DISCOVERY DEADLINES

Plaintiffs,

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Civil Action No. 1:09-cv-1273-LJO-MJS

PERINATAL MEDICAL GROUP, INC.,
KRISHNAKUMAR RAJANI, M.D., and
STEPHEN ELLIOT, M.D.,

STIPULATED TO THE SAME, the Court finds that the above-stated SECOND

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STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES is sanctioned by the
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Court, and, based upon that stipulation,

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THE COURT HEREBY ORDERS AS FOLLOWS:

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1.

The Court’s scheduling order, and first amendment of that order, is hereby

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[PROPOSED] ORDER ON SECOND STIPULATION EXTENDING DISCOVERY DEADLINES

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amended by this second amendment to reflect the parties’ stipulation as follows:

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EVENT
Disclosure of Expert Witnesses
Disclosure of Supplemental and/or
Rebuttal Expert Witnesses
Non-Expert Discovery Deadline
Expert Discovery Deadline
Non-Dispositive Motion Deadline

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AMENDED DEADLINE
August 1, 2011
August 29 2011
September 1, 2011
September 27, 2011
Filing: October 1, 2011
Hearing: On or before November 4, 2011

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Dated:

June 2, 2011

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:

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[PROPOSED] ORDER ON SECOND STIPULATION EXTENDING DISCOVERY DEADLINES