Staggs et al v. Doctors Hospital of Manteca, Inc. et al

Filing 129

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 1/11/16 ORDERING that the hearing on Plaintiffs' MOTION to STRIKE 126 is CONTINUED to 2/25/2016 at 02:00 PM in Courtroom 7 (MCE) before Chief Judge Morrison C. England Jr. The dates for filing opposition and reply papers are to be based on the new hearing date of 2/25/16.(Mena-Sanchez, L)

1 Michael R. Mordaunt, Esq., Bar No. 66911
Stephanie Roundy, Esq., Bar No. 211871
2 RIGGIO MORDAUNT & KELLY
A Professional Law Corporation
3 2509 West March Lane, Suite 200
Stockton, CA 95207
4 Telephone: [phone]
5 Attorneys for Defendants
MARIO P. SATTAH, M.D., LINCOLN RUSSIN, M.D.
6 AND JAMES P. OWEN, M.D.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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Riggio Mordaunt & Kelly
2509 W March Lane
Suite 200
Stockton, CA 95207
[phone]

LINNIE STAGGS, as Administrator of
) Case No. 2:11-CV-00414-MCE-KJN
the ESTATE OF ROBERT E. STAGGS, )
deceased, and MELISSA STAGGS
) STIPULATION FOR CONTINUANCE OF
) PLAINTIFFS’ MOTION TO STRIKE
Plaintiff(s),
) AFFIRMATIVE DEFENSES AND PROPOSED
) ORDER
vs.
)
)
DOCTOR'S HOSPITAL OF
) Action Filed: February 14, 2011
MANTECA, INC., IVAN CLAY,
)
Warden, TIM VIRGA, Interim Warden, )
FRANK X. CHAVEZ, Warden,
)
SHARON AUNGST, JACK ST.
)
CLAIR, M.D., CURTIS ALLEN, M.D., )
EDWIN BANGI, M.D., JOHN KRPAN, )
D.O., JONATHAN BENAK, PA,
)
LINCOLN RUSSIN, M.D., JAMES P.
)
OWEN, M.D., MARIO P. SATTAH,
)
M.D. and DOES 1 through 100,
)
inclusive
)
)
Defendant(s).
)
)
Pursuant to Local Rules 143, 144 and 230(f), plaintiffs and defendants Lincoln Russin,

27 M.D. and James P. Owen, M.D., by and through their counsel of record, agree to continue the
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STIPULATION FOR CONTINUANCE OF PLAINTIFF’S
MOTION TO STRIKE AFFIRMATIVE DEFENSES AND PROPOSED ORDER

1 hearing on plaintiffs’ Motion to Strike Affirmative Defenses (ECF No. 126) to February 25, 2016
2 at 2:00 p.m. in Courtroom 7. The motion is currently scheduled for January 28, 2016. There have
3 not been any previous continuances of this motion.
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Defense counsel currently represents three defendants, Mario Sattah, M.D., Lincoln Russin,

5 M.D. and James P. Owen, M.D. There is good cause to continue the Motion to Strike because new
6 defense counsel is being obtained for two of these three defendants. The continuance is necessary
7 in order to retain new defense counsel and allow new counsel to become familiar with the case and
8 issues relevant to the motion to strike. Good cause to continue the hearing also exists to allow time
9 for new defense counsel to meet and confer with plaintiffs’ counsel as to issues raised in the motion
10 to strike. The parties stipulate to a continuance of the hearing on plaintiff’s Motion to Strike
11 Affirmative Defenses to February 25, 2016 at 2:00 p.m. in Courtroom 7.
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The parties further stipulate that the dates for filing opposition and reply papers are to be

13 based on the new hearing date of February 25, 2016.
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IT IS SO STIPULATED.

15 Dated: December 29, 2015

RIGGIO MORDAUNT & KELLY

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By:

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21 Dated: December __, 2015

(S) Stephanie Roundy
Stephanie Roundy, Esq.
Attorneys for Defendant
MARIO P. SATTAH, M.D. LINCOLN
RUSSIN, M.D. and JAMES P. OWEN,
M.D.

U.C. DAVIS CIVIL RIGHTS CLINIC

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By:__ (S) Carter C. White_______
Carter C. White, Esq.
Supervising Attorney
Attorneys for Plaintiffs

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Riggio Mordaunt & Kelly
2509 W March Lane
Suite 200
Stockton, CA 95207
[phone]

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STIPULATION FOR CONTINUANCE OF PLAINTIFF’S
MOTION TO STRIKE AFFIRMATIVE DEFENSES AND PROPOSED ORDER

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ORDER
Good cause appearing, the parties’ stipulated request for a continuance of the hearing on

3 plaintiffs’ Motion to Strike Affirmative Defenses to February 25, 2016 at 2:00 p.m. in Courtroom 7
4 (ECF No. 128) is GRANTED.
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The dates for filing opposition and reply papers are to be based on the new hearing date of

6 February 25, 2016.
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IT IS SO ORDERED.

8 Dated: January 11, 2016
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Riggio Mordaunt & Kelly
2509 W March Lane
Suite 200
Stockton, CA 95207
[phone]

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STIPULATION FOR CONTINUANCE OF PLAINTIFF’S
MOTION TO STRIKE AFFIRMATIVE DEFENSES AND PROPOSED ORDER