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)

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1 GERI LYNN GREEN (SBN 127709) LAW OFFICE OF GERI LYNN GREEN 2 4 Embarcadero Center, Suite 1400 San Francisco, California 94111 3 Tel: (415) 982-2600 Fax: (415) 358-4562 4 greenlaw700@gmail.com gerilynngreen@gmail.com 5 Attorney for Plaintiff 6 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: 916-974-8500 Fax: 916 974-8510 10 Attorneys for Defendants County of Sacramento, John McGinness, Deputy Stephanie Jacoby, Deputy Mark Medeiros 11 12 13 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA -SACRAMENTO DIVISION 14 15 SANDIPKUMAR TANDEL, Plaintiffs, 16 v. COUNTY OF SACRAMENTO, et al, 17 Defendants. 18 19 20 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. 23 24 25 26 27 28 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 Page |1 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. 5 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 8 /S/: Geri Green GERI GREEN Attorney for Plaintiff Sandipkumar Tandel 9 10 11 12 13 Dated: April 5, 2017 14 LONGYEAR, O’DEA & LAVRA, LLP /S/: Van Longyear VAN LONGYEAR Attorneys for Defendants, County of Sacramento, et al. 15 16 17 18 19 20 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. 22 IT IS SO ORDERED. 23 Dated: April 5, 2017 24 25 26 27 28 Joint Stipulation and Order CASE NO. 2:11-CV-00353-MCE AC Page |2

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