Fuentes v. John C. Fremont Healthcare District

Filing 21

AMENDED Stipulation and Order to extend Defendant's time to respond to the complaint and continue the initial case management conference, signed by Magistrate Judge Gary S. Austin on 10/9/2014. (Response due by 11/5/2014; Scheduling Conference previously set for 10/15/2014 has been CONTINUED to 12/3/2014 at 10:00 AM in Courtroom 10 (GSA) before Magistrate Judge Gary S. Austin)(Figueroa, O)

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MICHAEL T. LUCEY (SBN: 099927)
HEATHER A. IRWIN (SBN: 203203)
GORDON & REES LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants
DEFENDANT JOHN C. FREMONT
HEALTHCARE DISTRICT

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UNITED STATES DISTRICT COURT

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EASTERN OF CALIFORNIA

Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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UNITED STATES OF AMERICA, ex rel. and )
Plaintiff MARIA ELENA FUENTES, M.D. )
)
Plaintiffs,
)
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vs.
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JOHN C. FREMONT HEALTHCARE
)
DISTRICT, and DOES 1-50,
)
)
Defendant.
)

CASE NO. 1:13-CV-00234-LJO-GSA
AMENDED STIPULATION AND
ORDER TO EXTEND DEFENDANT’S
TIME TO RESPOND TO THE
COMPLAINT AND CONTINUE THE
INITIAL CASE MANAGEMENT
CONFERENCE

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Whereas, following extensive prelitigation efforts to resolve this matter, the parties

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continue to discuss settlement and believe with some brief additional time they may be able to

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resolve the case without the court’s assistance; and,
Whereas, Defendant’s responsive pleading is due and the Mandatory Scheduling

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Conference is set for October 15;
Therefore, the parties through their attorneys, stipulate to continue Defendant’s time to

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respond to the complaint by 30 days until November 5, 2014, and request that the Mandatory

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Scheduling Conference be continued by 49 days until December 3, 2014.

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-1AMENDED STIPULATION AND ORDER TO EXTEND DEFENDANT’S TIME TO RESPOND TO THE COMPLAINT
AND CONTINUE THE INITIAL CASE MANAGEMENT CONFERENCE

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Dated: October 9, 2014

GORDON & REES LLP

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By:

/s/ Heather A. Irwin
Heather A. Irwin
Attorneys for Defendants
DEFENDANT JOHN C. FREMONT
HEALTHCARE DISTRICT

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Dated: October 8, 2014

PHYSICIANS’ ADVOCATES

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By:

/s/ Charles Bond
Charles Bond
Attorneys for Relator and Plaintiff
Maria Elena Fuentes, M.D.

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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Good cause appearing therefore based upon the above stipulation of the parties, IT IS
ORDERED that Defendant shall have until November 5, 2014, to respond to the complaint, and
the Mandatory Scheduling Conference is continued to December 3, 2014, at 10:00 before
Magistrate Gary S. Austin.

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IT IS SO ORDERED.
Dated:

October 9, 2014

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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1081793/21025385v.1

-2AMENDED STIPULATION AND ORDER TO EXTEND DEFENDANT’S TIME TO RESPOND TO THE COMPLAINT
AND CONTINUE THE INITIAL CASE MANAGEMENT CONFERENCE