Bodi v. Shingle Springs Band of Miwok Indians

Filing 25

STIPULATION and ORDER 24 continuing deadlines and briefing schedule signed by Judge Lawrence K. Karlton on 8/14/2013. Plaintiff shall file her Opposition to defendant's 18 Motion to Dismiss no later than 9/12/2013. Defendants shall file any Reply Brief in support of 18 Motion by 9/27/2013. Status Conference is RE-SCHEDULED for 10/21/2013 at 1:30 PM in Courtroom 4 (LKK). (Marciel, M)

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PACIFIC AMERICAN LAW GROUP, PC
David Nied (SBN 136413)
Wendy L. Hillger (SBN 178682)
582 Market Street, Suite 2009
San Francisco, CA 94104
Telephone: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff Beth A. Bodi

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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BETH A. BODI,
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Case No. 2:13-CV-01044 LKK-CKD

Plaintiff,

STIPULATION AND ORDER
CONTINUING THE STATUS
CONFERENCE AND SCHEDULING
THE OPPOSITION AND REPLY
BRIEFING RE DEFENDANTS’
MOTION TO DISMISS

vs.
SHINGLE SPRINGS BAND OF MIWOK
INDIANS; SHINGLE SPRINGS TRIBAL
HEALTH PROGRAM; SHINGLE SPRINGS
TRIBAL HEALTH; BRENDA ADAMS (as
current Chairperson of the Shingle Springs
Tribal Health Board), and DOES 1 through
30, inclusive,

The Hon. Lawrence K. Karlton
Complaint Filed: April 22, 2013

Defendants.

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Plaintiff Beth A. Bodi and defendants Shingle Springs Band Of Miwok Indians, Shingle

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Springs Tribal Health Program, Shingle Springs Tribal Health Board, and Brenda Adams, by and

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through their counsel of record respectfully request that the court continue the August 19, 2013

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Status Conference until October 7, 2013, and give effect to the stipulation regarding the briefing

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schedule for defendants’ Motion to Dismiss, as follows:

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CASE NO. 2:13-CV-01044 LKK-CKD

STIPULATION AND ORDER CONTINUING THE
STATUS CONFERENCE AND SCHEDULING THE
OPPOSITION AND REPLY BRIEFING RE
DEFENDANTS’ MOTION TO DISMISS

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WHEREAS, this Court has previously scheduled the Status Conference for August 19,
2013;

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WHEREAS, the parties filed a Joint Status Report on or about August 5, 2013, seeking a

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continuance of the Status Conference to coincide with the hearing on defendants’ Motion to

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Dismiss;

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WHEREAS, all the above-listed defendants have filed a Motion to Dismiss, seeking

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dismissal of Plaintiff’s claims, with an initial hearing date of September 23, 2013, pursuant to the

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Parties stipulation;

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WHEREAS, the Court recently gave notice that the hearing date previously agreed upon

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between counsel is not available, and the Court thus re-calendared the hearing on defendants’

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Motion to Dismiss for October 7, 2013;

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WHEREAS, in light of the Court’s continuance of the hearing, the Parties wish to make

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arrangements for orderly filing of the Opposition and Reply briefing on a timeline that

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accommodates counsels’ respective schedules and other trial work; and

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WHEREAS, the Parties agree that the foregoing reasons present good cause for altering the

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briefing schedule set forth in Rule 230 of the Local Rules of the United States District Court,

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Eastern District of California.

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED among the Parties
that:
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Plaintiff shall oppose defendants’ motion to dismiss no later than September 12,

2013;
2.

Defendants shall file any reply brief in support of their motion to dismiss no later

than September 27, 2013;
3.

Counsel for plaintiff and defendants agree that it would be the best use of judicial

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and litigant resources to continue the Status Conference until October 7, 2013, to coincide with

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the new hearing date on defendants’ Motion to Dismiss.

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CASE NO. 2:13-CV-01044 LKK-CKD

STIPULATION AND ORDER CONTINUING THE
STATUS CONFERENCE AND SCHEDULING THE
OPPOSITION AND REPLY BRIEFING RE
DEFENDANTS’ MOTION TO DISMISS

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IT IS SO STIPULATED.

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Respectfully submitted,
Dated: August 13, 2013

PACIFIC AMERICAN LAW GROUP, PC

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By

/s/ Wendy L. Hillger (approved Aug. 13, 2013)
WENDY L. HILLGER

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Attorneys for Plaintiff
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Dated: August 13, 2013

DENTONS US LLP

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By

/s/ Ian R. Barker
IAN R. BARKER

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Attorneys for Defendants
SHINGLE SPRINGS BAND OF MIWOK
INDIANS, SHINGLE SPRINGS TRIBAL
HEALTH PROGRAM, SHINGLE SPRINGS
TRIBAL HEALTH BOARD, and BRENDA
ADAMS

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CASE NO. 2:13-CV-01044 LKK-CKD

STIPULATION AND ORDER CONTINUING THE
STATUS CONFERENCE AND SCHEDULING THE
OPPOSITION AND REPLY BRIEFING RE
DEFENDANTS’ MOTION TO DISMISS

ORDER

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The Parties having stipulated thereto and good cause appearing, IT IS HEREBY
ORDERED THAT:
1.

Plaintiff shall file her opposition to defendants’ motion to dismiss no later than

September 12, 2013;
2.

Defendants shall file any reply brief in support of their motion to dismiss no later

than September 27, 2013;
3.

The Status Conference shall be continued from August 19, 2013, to October 21,

2013, at 1:30 p.m.

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DATED: August 14, 2013.

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CASE NO. 2:13-CV-01044 LKK-CKD

STIPULATION AND ORDER CONTINUING THE
STATUS CONFERENCE AND SCHEDULING THE
OPPOSITION AND REPLY BRIEFING RE
DEFENDANTS’ MOTION TO DISMISS