Ireland v. Linder Psychiatric Group, Inc. et al

Filing 15

STIPULATION and ORDER signed by Judge John A. Mendez on 11/18/15 ORDERING that the schedule is as follows: Designation of Expert Witnesses due by 4/15/2016 with any supplemental disclosures due 04/09/16; Discovery due by 6/17/2016; Dispositive Mot ions filed by 07/26/16 and heard by 08/23/16; Final Pretrial Conference set for 10/7/2016 at 11:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez and Jury Trial set for 11/28/2016 at 09:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez. (Benson, A)

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Attorneys for Defendants
Linder Psychiatric Group, Inc.,
David Linder, M.D., and Renae Linder
Erick C. Turner, State Bar No. 236186
[e-mail]
Turner Law Group
1104 Corporate Way
Sacramento, CA 95831
Telephone: [phone]

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Brian S. Crone, State Bar No. 191731
[e-mail]
The Law Office of Brian Crone
1104 Corporate Way
Sacramento, CA 95831
Telephone: [phone]

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Attorney for Plaintiff JAMIE IRELAND

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law corporation

weintraub tobin chediak coleman grodin

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Alden J. Parker, State Bar No. 196808
[e-mail]
Melissa M. Whitehead, State Bar No. 262123
[e-mail]
weintraub tobin chediak coleman grodin
LAW CORPORATION
400 Capitol Mall, 11th Floor
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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JAMIE IRELAND, an individual,
Plaintiff,
v.
LINDER PSYCHIATRIC GROUP, INC., a
California Corporation; DAVID LINDER,
M.D., an individual; RENAE LINDER, an
individual; and DOES 1 to 15,
Defendants.

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{1975128.DOC;}

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Case No. 2:15-cv-00670-JAM-EFB
STIPULATION AND ORDER MODIFYING
PRE-TRIAL SCHEDULING ORDER

Action Filed: December 31, 2014
First Amended Complaint: January 20,
2015
Action Removed: March 25, 2015

STIPULATION AND [PROPOSED] ORDER
MODIFYING PRE-TRIAL SCHEDULING ORDER

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Plaintiff JAMIE IRELAND (“Plaintiff”) and Defendants LINDER PSYCHIATRIC GROUP,

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INC., DAVID LINDER, M.D., and RENAE LINDER (collectively, “Defendants”), by and

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through their counsel of record, hereby submit the following stipulation and [proposed]

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Order to modify the Pre-Trial Scheduling Order (Dckt. # 13) to continue the trial, and all

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related deadlines and currently scheduled dates, as follows:

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WHEREAS the Parties have agreed to and scheduled mediation, to take place on
December 11, 2015;
WHEREAS the Parties have engaged in written discovery and have essential
depositions that have not yet been scheduled;
WHEREAS the expert witness disclosures deadline is December 4, 2015;

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WHEREAS the Parties agree that the time and expense associated with completing

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depositions and preparing expert witness disclosures will impede the ability to mediate

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and resolve this case;

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weintraub tobin chediak coleman grodin

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WHEREAS the Parties intend to conduct further discovery if mediation is not
successful;
WHEREAS the Parties and their counsel agree that an Order modifying the PreTrial Scheduling Order will not prejudice the Parties and can be issued forthwith;
WHEREAS the Parties and their counsel agree that this Stipulation is made in good
faith and not for any improper purpose;
WHEREAS there have been no previous modifications of the Pre-Trial Scheduling
Order in this matter;

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WHEREAS good cause exists to modify the scheduling order, to allow the Parties to

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meaningfully engage in further settlement discussions, private mediation, and to conduct

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further discovery if the Parties do not reach a settlement.

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NOW THEREFORE, IT IS HEREBY STIPULATED by and between the Parties, that:

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1.

All dates in the Scheduling Order will be continued, subject to Court

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approval, to allow the Parties to meaningfully engage in further settlement discussions,

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private mediation, and to conduct further discovery if the Parties do not reach a
{1975128.DOC;}

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STIPULATION AND [PROPOSED] ORDER
MODIFYING PRE-TRIAL SCHEDULING ORDER

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settlement. The Parties propose ///

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the following new scheduling deadlines and dates, which are mutually agreeable to the

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Parties, or dates thereafter:
Expert Witness Disclosures:

April 15, 2016

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Supplemental Expert Witness Disclosures:

April 29, 2016

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Discovery Cut-Off:

June 17, 2016

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Dispositive Motion Filing Deadline:

July 26, 2016

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Dispositive Motion Hearing Deadline:

August 23, 2016 at 1:30 p.m.

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Final Pretrial Conference:

October 7, 2016 at 11:00 a.m.

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Jury Trial:

November 28, 2016 at 9:00 a.m.

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2.

The Parties agree to accept these proposed dates, or such later dates as the

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Court may reasonably set in its discretion, subject to any subsequent adjustment

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necessary for good cause shown.

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weintraub tobin chediak coleman grodin

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3.

Based on the foregoing, the Parties respectfully request this Court enter an

Order consistent with this Stipulation.
IT IS SO STIPULATED.
Dated: November 17, 2015

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Erick C. Turner, Attorney At Law
By:

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Erick C. Turner
Attorney for Plaintiff
JOELLE STALLSMITH

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/s/ Erick C. Turner

Dated: November 17, 2015

weintraub tobin chediak coleman grodin
LAW CORPORATION

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By:

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/s/ Alder J. Parker
Alden J. Parker
Attorneys for Defendant
LINDER PSYCHIATRIC GROUP, INC.

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{1975128.DOC;}

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STIPULATION AND [PROPOSED] ORDER
MODIFYING PRE-TRIAL SCHEDULING ORDER

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ORDER (AS AMENDED BY THE COURT)

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Based upon the Stipulation of the parties and good cause appearing therefore, IT IS SO
ORDERED.
Dated: 11/18/2015

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/s/ John A. Mendez________________________
UNITED STATES DISTRICT COURT JUDGE

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weintraub tobin chediak coleman grodin

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{1975128.DOC;}

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STIPULATION AND [PROPOSED] ORDER
MODIFYING PRE-TRIAL SCHEDULING ORDER