Stallsmith v. Linder Psychiatric Group, Inc. et al

Filing 34

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 5/24/2016 ORDERING that the Discovery cut-off is CONTINUED to 7/27/2016. Law and Motion cut-off is CONTINUED to 9/28/2016. Pretrial conference is CONTINUED to 1/11/2017 at 11:00 AM in Courtroom 24 (CKD) before Magistrate Judge Carolyn K. Delaney. Trial is CONTINUED to 2/6/2017 at 09:00 AM in Courtroom 24 (CKD) before Magistrate Judge Carolyn K. Delaney. (Zignago, K.)

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Alden J. Parker, State Bar No. 196808
Email: [e-mail]
Alexa R. Greenbaum, State Bar No. 293736
Email: [e-mail]
FISHER & PHILLIPS LLP
1215 K Street, 17th Floor
Sacramento, CA 95814
Telephone [phone]
Facsimile [phone]
Attorneys for Defendants
LINDER PSYCHIATRIC GROUP, INC.,
DAVID LINDER, M.D., RENAE LINDER
ERICK C. TURNER, State Bar No. 236186
TURNER LAW GROUP
1104 Corporate Way
Sacramento, CA 95831
Telephone: [phone]
[e-mail]

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BRIAN S. CRONE, State Bar No. 191731
THE LAW OFFICE OF BRIAN CRONE
1104 Corporate Way
Sacramento, CA 95831
Telephone: [phone]
[e-mail]

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Attorneys for Plaintiff JOELLE STALLSMITH

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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JOELLE STALLSMITH, on behalf of
herself and all others similarly situated,

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Plaintiff,

Case No. 2:15-cv-00667-CKD
STIPULATION AND ORDER TO
EXTEND TRIAL AND DEADLINES

v.
LINDER PSYCHIATRIC GROUP,
INC., a California Corporation; DAVID
LINDER, M.D., an individual; RENAE
LINDER, an individual; and DOES 1 to
100, inclusive,
Defendants.

Action Filed: November 18, 2014

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Defendants Linder Psychiatric Group, Inc., David Linder, M.D., and Renae
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STIPULATION AND [PROPOSED] ORDER
TO EXTEND TRIAL AND DEADLINES

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Linder (“Defendants”) and Joelle Stallsmith (“Plaintiff”), by and through their

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respective counsel, hereby stipulate as follows:

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WHEREAS, on July 2, 2015, the Status (Pretrial Scheduling) Order was filed.

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WHEREAS, Trial in the instant action is currently scheduled for September

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26, 2016.
WHEREAS, the Final Pretrial Conference is currently scheduled for July 27,

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2016.

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WHEREAS, all pretrial law and motion shall be completed by June 29, 2016.

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WHEREAS, the Parties are engaging in good faith early settlement

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discussions;

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WHEREAS, the Parties have recently agreed to explore potential resolution

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of this matter through the Court’s Voluntary Dispute Resolution Program

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(“VDRP”).

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WHEREAS, the Parties desire to focus their efforts and resources on potential

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resolution of this matter and postpone costly trial preparation for a brief period of

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time;

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WHEREAS, the Parties agree that there is good cause to continue the trial

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date and all applicable deadlines for at least ninety (90) days in order to facilitate

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good faith settlement negotiations between the Parties without incurring

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unnecessary costs and fees associated with trial preparation;
WHEREAS, continuance is necessary to avoid the Parties incurring

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unnecessary filing costs;

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WHEREAS, this Stipulation is not entered into with the intent to delay. By

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continuing of the trial and applicable deadlines, there will be no prejudice to any

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party or to any of the witnesses involved in the case;
WHEREAS, the Parties have not previously sought any prior continuances;

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and
WHEREAS, the current trial date has not been previously continued by this
STIPULATION AND [PROPOSED] ORDER
TO EXTEND TRIAL AND DEADLINES

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Court.
STIPULATION

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IT IS HEREBY STIPULATED by all Parties, through their respective

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counsel, that:

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1.

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The trial of this matter be continued from September 26, 2016 to

February 6, 2017, or to a later date decided upon by the Court.
2.

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The deadline for all pretrial law and motion shall be continued at least

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(90) days from June 29, 2016 to September 29, 2016, or a later date decided upon by

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the Court.
3.

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All pre-trial deadlines and dates shall be extended in accordance with

the new trial date.
4.

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This Stipulation may be executed in counterparts, each of which shall

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be deemed an original and all of which shall constitute one and the same Stipulation.

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IT IS SO STIPULATED.
STIPULATION AND [PROPOSED] ORDER
TO EXTEND TRIAL AND DEADLINES

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Date: May 20, 2016

FISHER & PHILLIPS LLP

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By:

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/s/ Alden J. Parker
Alden J. Parker
Attorneys for Defendants
LINDER PSYCHIATRIC GROUP, INC.,
DAVID LINDER, M.D., RENAE LINDER

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Dated: May 20, 2016

THE LAW OFFICE OF BRIAN CRONE

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By:

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/s/ Brian Crone
Brian Crone
Attorney for Plaintiff
JOELLE STALLSMITH

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Discovery cut-off is continued to July, 27, 2016.

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Law and motion cut-off is continued to September 28, 2016.

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Pretrial conference is continued to January 11, 2017 at 11:00 a.m.
Trial is continued to February 6, 2017 at 9:00 a.m.

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Dated: 05/24/16

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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE
STIPULATION AND [PROPOSED] ORDER
TO EXTEND TRIAL AND DEADLINES

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