Tandel v. County of Sacramento, et al

Filing 202

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 11/07/2016 ORDERING that the deadline to file dispositional documents is EXTENDED to 2/2/2017. (Jackson, T)

1 GERI LYNN GREEN (SBN 127709)
LAW OFFICE OF GERI LYNN GREEN
2 4 Embarcadero Center, Suite 1400
San Francisco, California 94111
3 Tel: [phone]
Fax: [phone]
4 [e-mail]
[e-mail]
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Attorney for Plaintiff
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LONGYEAR, O’DEA & LAVRA, LLP
7 VAN LONGYEAR, CSB NO. 84189
PETER C. ZILAFF, CSB NO. 272658
8 3620 American River Drive, Suite 230
Sacramento, California 95864-5923
9 Tel: [phone] Fax: [phone]
10 Attorneys for Defendants County of Sacramento,
John McGinness, Deputy Stephanie Jacoby, Deputy Mark Medeiros
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA -SACRAMENTO DIVISION

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15 SANDIPKUMAR TANDEL,
Plaintiffs,
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v.
17 COUNTY OF SACRAMENTO, et al,
Defendants.
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Case No. 2:11-CV-00353-MCE AC
STIPULATION; AND ORDER FOR
EXTENSION OF TIME TO FILE
DISMISSAL

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Plaintiff, Sandipkumar Tandel, is represented by Geri Green of the Law Office of Geri
Lynn Green. Defendants, County of Sacramento, John McGinness, Deputy Stephanie Jacoby and
Deputy Mark Medeiros are represented by Van Longyear and Peter C. Zilaff of Longyear, O’Dea
& Lavra, LLP.
The parties have met and conferred and stipulate to extending the time for filing the
dismissal in this matter. The current deadline for filing the dismissal pursuant to the Court’s
Order (ECF No. 200) is November 2, 2016. Another extension of time to file closing documents
and the dismissal is necessary due to the extended negotiations with Medicare. The parties
stipulate to and request an extension of ninety days.

Joint Stipulation and Order
CASE NO. 2:11-CV-00353-MCE AC

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In order to complete the settlement, both sides require a final payment amount from
Medicare. Due to the rarity and lack of knowledge of Neuro Myelitis Optica, the disease which
has caused Plaintiff’s profound spinal cord damage, the agency is engaging in lengthy and
detailed reviews of information. Consequently, Plaintiff’s counsel has continued providing the
agency with information, however it is taking an inordinate amount of time to resolve this issue.
In light of time Medicare requires to respond, it is respectfully requested that the Court set the
date for the filing of disposition documents to February 2, 2017.
Accordingly, the parties, through their counsel, stipulate to and request an order extending
the deadline to file closing documents to February 2, 2017.
Dated: November 1, 2016

LAW OFFICE OF GERI LYNN GREEN

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/S/: Geri Green
GERI GREEN
Attorney for Plaintiff
Sandipkumar Tandel

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16 Dated:November 1, 2016

LONGYEAR, O’DEA & LAVRA, LLP

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/S/: Van Longyear
VAN LONGYEAR
Attorneys for Defendants,
County of Sacramento, et al.

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ORDER

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Pursuant to the parties’ stipulation, and good cause appearing, the deadline to file
dispositional documents is extended to February 2, 2017.
IT IS SO ORDERED:
Dated: November 7, 2016

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Joint Stipulation and Order
CASE NO. 2:11-CV-00353-MCE AC

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