Tandel v. County of Sacramento, et al

Filing 206

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 4/5/2017 ORDERING the deadline by which the parties shall file dispositional documents shall be CONTINUED to 5/3/2017. (Washington, S)

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.
COUNTY OF SACRAMENTO, et al,
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Defendants.
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Case No. 2:11-CV-00353-MCE AC
STIPULATION; AND ORDER FOR
EXTENSION OF TIME TO FILE
DISMISSAL TO MAY 3, 2017

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

21 Deputy Mark Medeiros are represented by Van Longyear and Peter C. Zilaff of Longyear, O’Dea
22 & Lavra, LLP.
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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. 204) is April 3, 2016. Another extension of time to file closing documents and
the dismissal is necessary due to the extended negotiations with Medicare and Medi-Cal. The
parties stipulate to and request an extension of thirty days.
In order to complete the settlement, both sides require a final payment amounts from

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

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1 Medicare and Medi-Cal. Both Medicare and Medi-Cal have determined that they will not pursue
2 any lien, however Medi-Cal is still in the process of preparing a letter of confirmation.
3 Consequently, it is respectfully requested that the Court set the date for the filing of disposition
4 documents to May 3, 2017 in order to finalize all the paperwork.
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Accordingly, the parties, through their counsel, stipulate to and request an order extending

6 the deadline to file closing documents to May 3, 2017.
7 Dated: April 5, 2017

LAW OFFICE OF GERI LYNN GREEN

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

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Dated: April 5, 2017

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LONGYEAR, O’DEA & LAVRA, LLP

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

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ORDER
Pursuant to the stipulation of the parties and good cause appearing, the deadline by which

21 the parties shall file dispositional documents shall be continued to May 3, 2017.
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IT IS SO ORDERED.

23 Dated: April 5, 2017
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Joint Stipulation and Order
CASE NO. 2:11-CV-00353-MCE AC

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