Chopourian v. Catholic Healthcare West et al

Filing 317

STIPULATION and ORDER signed by Judge Kimberly J. Mueller on 4/3/2012 re 316 Stipulation and Proposed Order; ORDERING execution on the judgment shall be STAYED 30 days after the Court enters its orders disposing of defendant's motions for new trial and/or JMOL and/or for a remittitur; any applicable deadlines for filing a costs bill or motion for attorney's fees shall be extended until 30 days after the Court enters its order disposing of defendants motions for new trial and/or JMOL and/or for remittitur. (Waggoner, D)

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JUDITH CLARK MARTIN, STATE BAR NO. 173557
MARY E. “MOLLY” GREENE, STATE BAR NO. 186205
LA FOLLETTE, JOHNSON,
DE HAAS, FESLER & AMES
655 University Avenue, Suite 119
Sacramento, California 95825
Phone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
Email:
[e-mail]

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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RAYMOND A. CARDOZO, STATE BAR NO. 173263
[e-mail]
MARGARET A. GRIGNON, STATE BAR NO. 67721
[e-mail]
PAUL D. FOGEL, STATE BAR NO. 70859
[e-mail]
REED SMITH LLP
101 Second Street, Ste. 1800
San Francisco, CA 94105
Telephone:
415 543 8700
Facsimile:
415 391 8269

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Attorneys for Defendant,
CATHOLIC HEALTHCARE WEST dba
MERCY GENERAL HOSPITAL (erroneously
sued and served herein as CATHOLIC HEALTHCARE
WEST and MERCY GENERAL HOSPITAL)

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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ANI CHOPOURIAN,
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Plaintiff,
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v.

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CATHOLIC HEALTHCARE WEST,
MERCY GENERAL HOSPITAL, AND
DOES 1 through 20, inclusive,

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Defendants.

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CASE NO. 2:09-CV-02972-KJM-KJN
STIPULATION TO STAY EXECUTION
ON JUDGMENT AND DEFERRING
DEADLINE TO SEEK RECOVERY OF
COSTS AND ATTORNEY’S FEES
PENDING POST-TRIAL MOTIONS;
ORDER
Honorable Kimberly J. Mueller

After the Court enters judgment, the parties anticipate that Defendant will file motions for
judgment as a matter of law and/or for a new trial and/or for a remittitur. Defendant desires a stay of

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execution of the judgment until after such motions are decided by the Court, and Plaintiff desires to

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defer her filing of a costs bill and motion for attorney’s fees until after such motions are decided.

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Accordingly, the parties stipulate that (1) execution on the judgment shall be stayed until 30 days

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after the Court enters its order(s) disposing of Defendant’s motions for new trial and/or JMOL

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and/or for a remittitur, and (2) any applicable deadlines for filing a costs bill or motion for attorney’s

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fees shall be extended until 30 days after the Court enters its order(s) disposing of Defendant’s

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motions for new trial and/or JMOL and/or for a remittitur .

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Dated: April 2, 2012.

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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LA FOLLETTE, JOHNSON,
DE HAAS, FESLER & AMES
REED SMITH LLP

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By:

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/s/ Raymond A. Cardozo
RAYMOND A. CARDOZO

Attorneys for Defendant CATHOLIC HEALTHCARE
WEST dba MERCY GENERAL HOSPITAL
(erroneously sued and served herein as CATHOLIC
HEALTHCARE WEST and MERCY GENERAL
HOSPITAL)

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Dated: April 2, 2012.

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BOHM LAW GROUP
THE LAW OFFICES OF GREGORY R.
DAVENPORT

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LAW OFFICE OF ERIKA M. GASPAR

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By:

/s/ Lawrence A. Bohm
LAWRENCE A. BOHM

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Attorneys for Plaintiff Ani Chopourian
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IT IS SO ORDERED.

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Dated: April 3, 2012.
UNITED STATES DISTRICT JUDGE

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-2STIPULATION TO STAY EXECUTION ON JUDGMENT AND DEFER COST/FEE
DEADLINE; ORDER