Doctors Medical Center of Modesto, Inc. v. Global Excel Management, Inc., et al.

Filing 6

STIPULATION AND ORDER Extending the Response Deadline to the Complaint, signed by Magistrate Judge Barbara A. McAuliffe on 10/13/2020. ( Case Management Deadline: 11/23/2020) (Martin-Gill, S)

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1 WARREN TERZIAN LLP Dan Terzian (SBN 283835) 2 dan.terzian@warrenterzian.com 700 S. Flower St., Suite 1000 3 Los Angeles, CA 90017 T: (213) 410-2620 4 Counsel for Defendant 5 Global Excel Management, Inc. 6 7 8 9 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 10 11 Doctors Medical Center of Modesto, Inc., a California corporation, 12 Plaintiff, 13 v. 14 Global Excel Management, Inc., a 15 Canadian corporation; Mutuelle 16 Assurance Des Commercants Et Industriels De France Et Des 17 Cadres Et Des Salariê De L’industrie Et Du Commerce doing 18 business as MACIF, a French corporation; BNP Paribas S.A., a 19 French corporation, and Does 1 ) through 25, inclusive, 20 21 Case No. 1:20-cv-01425-AWI-BAM Stipulation and Order Extending the Response Deadline to the Complaint Defendants. 22 23 24 25 26 27 28 1 Stipulation and Order Extending Response Deadline to Complaint 1 Plaintiff Doctors Medical Center of Modesto, Inc. and Defendant Global Excel 2 Management, Inc. stipulate to extend Global Excel’s response to the complaint to 3 November 23, 2020. The Parties request a court order granting this Stipulation. 4 The reasons for this Stipulation are as follows: 5 1. Doctors Medical and Global Excel are currently engaging in settlement 6 discussions that would resolve this entire case. These settlement discussions require 7 obtaining records from various foreign companies. 8 2. The parties are more likely to reach a negotiated resolution with an 9 extension to Global Excel’s response deadline. Global Excel intends to file a motion to 10 quash service of the summons for lack of personal jurisdiction. Without an extension, 11 Global Excel would soon be forced to incur fees to file that motion. Incurring those fees 12 would hurt the likelihood of reaching an early negotiated resolution. 13 3. Global Excel was served on September 23, 2020. Its current response 14 deadline to the complaint is October 23, 2020. 15 16 Dated: October 7, 2020 WARREN TERZIAN LLP 17 s/ Dan Terzian Dan Terzian 18 19 Counsel for Defendant Global Excel Management, Inc. 20 21 22 23 24 25 26 Dated: October 7, 2020 HELTON LAW GROUP s/ Kim Worobec (as authorized on October 6) Kim Worobec Counsel for Plaintiff Doctors Medical Center of Modesto, Inc. 27 28 2 Stipulation and Order Extending Response Deadline to Complaint 1 2 ORDER Pursuant to the parties’ stipulation, the deadline for Defendant Global Excel Management, 3 Inc. to file and serve an answer or other responsive pleading to the complaint is HEREBY 4 EXTENDED to November 23, 2020. 5 The parties are advised that further extensions will require a showing of good cause. Good 6 cause may consist of the inability to comply with court orders in light of the COVID-19 pandemic. 7 Any such future difficulties should be explained. 8 IT IS SO ORDERED. 9 10 Dated: October 13, 2020 /s/ Barbara A. McAuliffe _ UNITED STATES MAGISTRATE JUDGE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 Stipulation and Order Extending Response Deadline to Complaint

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