Chopourian v. Catholic Healthcare West et al

Filing 30

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 4/6/11 ORDERING non-expert discovery cut-off set for 7/5/11; expert discovery cut-off set for 8/12/11; expert disclosure date set for 7/19/11; final pretrial conference set for 8/10/2011 at 10:00 AM in Courtroom 3 (KJM) before District Judge Kimberly J. Mueller and the joint pretrial statement due 8/3/11. (Carlos, K)

-KJN Chopourian v. Catholic Healthcare West et al

Doc. 30

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

LAWRANCE A. BOHM, (SBN 208716) BOHM LAW GROUP 4600 Northgate Blvd Suite 210 Sacramento, CA 95834 Telephone: [phone] Facsimile: [phone] ERIKA M. GASPAR, (SBN 238117) LAW OFFICE OF ERIKA M. GASPAR 2121 Natomas Crossing Drive, Suite 200-399 Sacramento, CA 95834 Telephone [phone] Facsimile [phone] Attorneys for Plaintiff ANI CHOPOURIAN UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

ANI CHOPOURIAN, Case No. 2:09-CV-02972-KJM-KJN Plaintiff, v. CATHOLIC HEALTHCARE WEST, MERCY GENERAL HOSPITAL, AND DOES 1 through 20, inclusive, Defendants. STIPULATION AND ORDER EXTENDING THE DEADLINES OF THE STATUS (PRETRIAL SCHEDULING) ORDER

Plaintiff, ANI CHOPOURIAN, by and through her attorneys of record, Lawrance A. Bohm and Erika M. Gaspar and Defendant, CATHOLIC HEALTHCARE WEST, by and through their attorney of record Judith Clark Martin stipulate to modify this Court's Status (Pretrial Scheduling) Order (Doc #20) of February 25, 2010 as modified by the Court on February 16, 2011 (Doc #27). 1
Chopourian v. Catholic Healthcare West, et al. Lawrance A. Bohm, Esq. Erika M. Gaspar, Esq.

Dockets.Justia.com

1 2 3 4

I.

EXISTENCE OF GOOD CAUSE 1. Good cause exists in that despite diligent efforts, the parties have been unable to

reschedule deposition of witnesses because of the trial schedules of attorneys for the parties. Attorney for Defendants Judith Clark Martin was unavailable for depositions in February as she

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 /// 28 2
Chopourian v. Catholic Healthcare West, et al. Lawrance A. Bohm, Esq. Erika M. Gaspar, Esq.

was in trial in San Joaquin County Superior Court. Plaintiff's attorneys, Lawrance A. Bohm and Erika M. Gaspar were assigned out to trial in Sacramento County Superior Court on March 15, 2011 on a case which was anticipated to continue into April. The case settled on March 28, 2011. Attorney for Defendants Judith Clark Martin is unavailable for depositions in April. Further, Mr. Bohm and Ms. Martin are both in trial on another matter in Butte County Superior Court from May 9 -19, 2011. 2. Good cause exists because Plaintiff still needs to take depositions of Defendants'

witnesses which were properly noticed and scheduled for February 2, 3, 4, 8, 9 and 10, and which Plaintiff has been unable to reschedule due to the scheduling conflicts of the attorneys as noted above. 3. Good cause exists in that Defendant is completing Plaintiff's deposition on

Monday, April 4, 2011, and the completion of Plaintiff's deposition may reveal additional discovery to be completed. Accordingly, both counsel request modifications to the Court's Status (Pretrial Scheduling) Order so that both parties can adequately prepare this case for trial currently scheduled for October 3, 2011. 4. Further good cause exists in that the date for disclosure of expert witnesses and

completion of expert discovery was not previously provided by the Court. 5. Further, neither party would be prejudiced by the requested modification to the

Court's Status (Pretrial Scheduling) Order.

1 2 3 4

II.

STIPULATION

For the foregoing reasons, the parties to this action hereby STIPULATE AS FOLLOWS: 1. That the following modifications be made to the Court's Status (Pretrial

Scheduling) Order: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3
Chopourian v. Catholic Healthcare West, et al. Lawrance A. Bohm, Esq. Erika M. Gaspar, Esq.

Previous Date: Non Expert Discovery Cut-Off Expert Disclosure Date Expert Discovery Cut-Off Final Pretrial Conference JOINT Pretrial Statement May 18, 2011 no date provided no date provided August 10, 2011 at 10:00 a.m. ** August 3, 2011**

New Date: July 5, 2011 July 19, 2011 August 12, 2011

**The parties request the court reschedule the Final PreTrial Conference accordingly. Dated: April 6, 2011 By: /s/ Lawrance A. Bohm Lawrance A. Bohm, Esq. Erika M. Gaspar, Esq. Attorneys for Plaintiff ANI CHOPOURIAN

By:

/s/ Judith Clark Martin

Judith Clark Martin Roy L. Westfall Attorneys for Defendant, CATHOLIC HEALTHCARE WEST
The court adopts the schedule proposed above and sets the final pretrial conference for August 25, 2011, with the joint pretrial statement due August 17, 2011. IT IS SO ORDERED: Date: April 6, 2011.
UNITED STATES DISTRICT JUDGE