Norman v. The Salvation Army

Filing 16

STIPULATION and ORDER 15 , signed by Judge John A. Mendez on 8/5/10, ORDERING that the physical exam of plltf Lenora Norman, shall proceed according to the terms of the parties' stipulation. (Kastilahn, A)

Norman v. The Salvation Army

Doc. 16

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STEVEN D. WERTH, # 121153 JENNY LI, # 216900 LOW, BALL & LYNCH 505 Montgomery Street, 7th Floor San Francisco, California 94111-2584 Telephone [phone] Facsimile [phone] Email: [e-mail] Email: [e-mail] Attorneys for Defendant THE SALVATION ARMY UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION LENORA NORMAN, ) ) Plaintiff, ) ) vs. ) ) THE SALVATION ARMY, a California ) Corporation, doing business as THE SALVATION ) ARMY ADULT REHABILITATION CENTER and ) THE SALVATION ARMY THRIFT STORE; ) DOES 1 through 50, inclusive, ) ) Defendants. ) ) ) Case No. 2:09-CV-03270-JAM-GGH STIPULATION AND ORDER FOR PHYSICAL EXAMINATION Judge: Hon. John A. Mendez Magistrate Judge: Hon. Gregory G. Hollows Date Complaint Filed: October 22, 2009

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The parties herein, through their attorneys of record, hereby agree and stipulate to the following: 20 (1) 21 Khasigian, at Dr. Khasigian's office, Pacific Evaluations Medical Group, 5030 J Street, Suite 300, 22 Sacramento, CA 95819 on August 31, 2010, at 11:00 a.m. Dr. Khasigian is a licensed physician 23 specializing in orthopedic surgery and medicine. 24 (2) 25 medical history relevant to the injuries she sustained in the accident on or about June 6, 2008, at 510 26 High Street, Auburn, California, that is the subject of this litigation; the mechanics of this accident; 27 medical causation relating to the injuries she suffered in this accident; any and all treatment and 28 diagnoses relating to the injuries she suffered in this accident; plaintiff's recovery from said injuries; and -1S T I P U L A T I O N AND ORDER FOR PHYSICAL EXAMINATION
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Plaintiff Lenora Norman ("plaintiff") shall submit to a physical examination by Dr. Harry

The examination by Dr. Khasigian shall include, and be limited to, a taking of plaintiff's

Case No. 2:09-CV-03270-JAM-GGH

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her residual complaints and symptoms, including present symptoms, the function of the areas affected by such accident, and the extent, if any, that any residual pain or discomfort has affected her daily activities. (3) At the time of said examination, plaintiff shall answer all proper questions submitted to

her by Dr. Khasigian, including, but not limited to, those relating to her medical history, prior injuries, and present symptoms, for purposes of Dr. Khasigian's evaluation and examination. (4) tests. (5) Dr. Khasigian will be provided with plaintiff's medical records and films by defense The examination shall not include any intrusive and/or painful testing, such as blood

counsel, which he will review prior and/or subsequent to his examination of plaintiff. (6) After the examination of plaintiff, Dr. Khasigian will prepare a written report of his

findings in conformance with F.R.C.P. Rule 35. A copy of such report will be provided to plaintiff's counsel upon request. (7) Defendant reserves the right to move for an order permitting a further physical

examination of plaintiff, which may include any issues and testing outside the scope of this stipulation.

Dated: August _____, 2010. LOW, BALL & LYNCH By

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STEVEN D. WERTH JENNY LI Attorneys for Defendant THE SALVATION ARMY

ELLIS, LAVOIE, POIRIER, STEINHEIMER, & MCGEE, LLP

THERESA M. LaVOIE Attorney for Plaintiff LENORA NORMAN

-2S T I P U L A T I O N AND ORDER FOR PHYSICAL EXAMINATION
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ORDER It is hereby ordered that the physical examination of plaintiff Lenora Norman, shall proceed according to the terms of the parties' stipulation, above. IT IS SO ORDERED.

Dated: August 5, 2010

/s/ John A. Mendez U. S. DISTRICT COURT JUDGE

Case No. 2:09-CV-03270-JAM-GGH