Goldman et al v. Carmichael Care and Rehabilitation Center et al

Filing 17

STIPULATION and ORDER signed by Judge John A. Mendez on 4/6/15 ORDERING that the deadline for the Parties to submit a joint status report is EXTENDED to 7/6/15. (Kastilahn, A)

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EDWARD P. DUDENSING (STATE BAR NO. 182221)
[e-mail]
The Law Office
1414 K Street, Suite 470
Sacramento, CA 95814
Telephone:
[phone]
Facsimile:
[phone]
NORMAN C. HILE (STATE BAR NO. 57299)
[e-mail]
MARC A. LEVINSON (STATE BAR NO. 57613)
[e-mail]
ORRICK, HERRINGTON & SUTCLIFFE LLP
400 Capitol Mall, Suite 3000
Sacramento, California 95814-4497
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiffs
Judy Goldman and Judy Goldman, individually

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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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EDWARD GOLDMAN, by and through his
successor-in-interest, JUDY GOLDMAN, and
JUDY GOLDMAN, individually,

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Plaintiff(s),

Case No. 2:15-cv-00432- JAM-AC
STIPULATION TO EXTEND
DEADLINE TO SUBMIT JOINT
STATUS REPORT FROM APRIL 27,
2015 TO JULY 6, 2015; ORDER

v.
CARMICHAEL CARE AND
REHABILITATION CENTER, SUN
HEALTHCARE GROUP, INC., SUNBRIDGE
HEALTHCARE CORP., REGENCY
HEALTH SERVICES, INC., CARMICHAEL
CARE, INC. dba ROSEWOOD TERRACE
CARE AND REHABILITIATION, NORTH
AMERICAN HEALTH CARE, INC., JOHN
SORENSEN, and DOES 1 through 50,
inclusive,

Date:
Time:
Ctrm:
Judge:

May 6, 2015
9:30 a.m.
6, 14th Floor
Hon. John A. Mendez

Defendant(s).

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STIPULATION TO EXTEND DEADLINE TO FILE
JOINT STATUS REPORT; [PROPOSED] ORDER

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RECITALS
The Court’s Order Requiring Joint Status Report [Dkt. No. 7] (the “Order”) compels the

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Plaintiffs and the Defendants (together, the “Parties”) to submit a joint status report within 60

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days of the February 24, 2015 removal of this action. As a result, the deadline for the Parties to

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submit a joint status report is April 27, 2015.

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Plaintiffs filed a Motion to Remand (“Motion”) on March 23, 2015. Plaintiffs selected a

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hearing date of May 6, 2015, the earliest available hearing date on the Court’s calendar.

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Defendants oppose the Motion.

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The Court’s ruling on the Motion may render the submission of a joint status report moot,
because if the Court grants the Motion, no joint status report will be necessary.

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In order to avoid unnecessary expense, the Parties wish to extend the deadline for

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submitting a joint status report from April 27, 2015 to and including July 6, 2015 (60 days after

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the May 6 hearing on the Motion). This is the first request for an extension of this deadline.

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STIPULATION
The Parties hereby stipulate to an extension of the deadline for submitting a joint status
report from April 27, 2015 to and including July 6, 2015.

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Dated: April 6, 2015

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EDWARD P. DUDENSING
Law Offices of Edward P. Dudensing
NORMAN C. HILE
MARC A. LEVINSON
Orrick, Herrington & Sutcliffe LLP

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By:

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/s/ Norman C. Hile
NORMAN C. HILE
Attorneys for Plaintiffs

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Dated: April 6, 2015

KRIKOR J. MESHEFEJIAN
Levene, Neale, Bender, Yoo & Brill L.L.P.

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By: /s/ Krikor J. Meshefejian (as authorized on 4/6/15)
KRIKOR J. MESHEFEJIAN
Attorneys for Defendants

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STIPULATION TO EXTEND DEADLINE TO FILE
JOINT STATUS REPORT; [PROPOSED] ORDER

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GOOD CAUSE HAVING BEEN SHOWN, the Court orders that the deadline for the

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Parties to submit a joint status report be extended from April 27, 2015, to and including July 6,

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2015.

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IT IS SO ORDERED.

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Dated: April 6, 2015

/s/ John A. Mendez____________
Hon. John A. Mendez
United States District Court Judge

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OHSUSA:761587077.1

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STIPULATION TO EXTEND DEADLINE TO FILE
JOINT STATUS REPORT; [PROPOSED] ORDER