San Joaquin General Hospital v. Cigna Healthcare of California, Inc. et al.

Filing 21

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 7/11/2017 EXTENDING the non-expert discovery cut-off to 11/3/2017. (Donati, J)

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LAW OFFICES OF STEPHENSON,
ACQUISTO & COLMAN, INC.
MELANIE JOY STEPHENSON-LAWS, ESQ. (SBN 113755)
BARRY SULLIVAN, ESQ.
(SBN 136571)
RICHARD A. LOVICH, ESQ. (SBN 113472)
KARLENE J. ROGERS-ABERMAN, ESQ. (SBN 237803)
BARBARA V. LAM, ESQ.
(SBN 231073)
303 N. Glenoaks Blvd., Suite 700
Burbank, CA 91502
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
SAN JOAQUIN GENERAL HOSPITAL

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SAN JOAQUIN GENERAL
Case No.: 2:16-cv-01921-MCE-EFB
HOSPITAL, a department of the County
of San Joaquin, a political subdivision of
the State of California,
STIPULATION AND
Plaintiffs,
ORDER TO EXTEND DISCOVERY
CUT-OFF DATES
v.
CIGNA HEALTHCARE OF
Trial Date: none set
CALIFORNIA, INC., a California for
profit corporation; CIGNA HEALTH &
LIFE INSURANCE COMPANY, a
Connecticut for profit corporation; and
DOES 1 - 25, INCLUSIVE,

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Defendants.

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15067

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STIPULATION AND
ORDER TO EXTEND DISCOVERY CUT-OFF
DATES

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The parties, Plaintiff SAN JOAQUIN GENERAL HOSPITAL and

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Defendants, CIGNA HEALTHCARE OF CALIFORNIA, INC. and CIGNA

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HEALTH & LIFE INSURANCE COMPANY, (“CIGNA”), through their

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respective attorneys of record, hereby jointly stipulate to a 120-day extension of

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the currently scheduled discovery deadlines as set forth below. Pursuant to Rule

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16, a party may seek modification of a scheduling order, including modification of

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a discovery cut-off date.

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WHEREAS, on July 6, 2016, Plaintiff filed the action in state court;

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WHEREAS, on August 12, 2016, CIGNA removed the action to this Court;

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WHEREAS , on August 15, 2016, the Court issued The Initial Pre-Trial

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Scheduling Order setting the current deadline to complete all non-expert discovery

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365 days from the filing of the original complaint in the action, i.e., July 6, 2017;

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WHEREAS, on June 20, 2017, the Court approved the Protective Order to

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allowing the parties to discovery relating to information that may contact trade

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secrets, confidential commercial, personal or financial information, and/or

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protected health information;

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WHEREAS, due to the number of patient claims at issue, the parties are
unable to complete the discovery process prior to the July 6, 2017 deadline;

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WHEREAS, trial date has not been set;

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WHEREAS, the parties believe the extension of discovery cut-off will not

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affect any other deadline established by the Court;

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WHEREAS, the parties have not made any previous request to extend any
discovery deadlines in this action;

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by
the parties through their undersigned counsel of record that:

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15067

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STIPULATION AND
ORDER TO EXTEND DISCOVERY CUT-OFF
DATES

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1.

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The non-expert discovery cut-off deadline is extended 120 days to
November 3, 2017.

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IT IS SO STIPULATED.

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Dated: July 3, 2017
LAW OFFICES OF STEPHENSON,
ACQUISTO & COLMAN, INC.

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By: /s/ Barbara V. Lam

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BARBARA V. LAM
Attorneys for Plaintiff
SAN JOAQUIN GENERAL HOSPITAL

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Dated: July 3, 2017
COLE PEDROZA LLP

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By: /s/ Tammy C. Weaver

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TAMMY C. WEAVER
Attorneys for Defendant
CIGNA HEALTHCARE OF
CALIFORNIA, INC. and CIGNA
HEALTH & LIFE INSURANCE
COMPANY

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Filing Attestation: I, Barbara V. Lam, hereby attest that I have received

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authorization for the electronic signature(s) indicated by a “conformed” signature

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(/s/) within this e-filed document.

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15067

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STIPULATION AND
ORDER TO EXTEND DISCOVERY CUT-OFF
DATES

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ORDER

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GOOD CAUSE APPEARING, the Court does find good cause to extend
non-expert discovery cut-off 120 days, to November 3, 2017.

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IT IS SO ORDERED.
Dated: July 11, 2017

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15067

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STIPULATION AND
ORDER TO EXTEND DISCOVERY CUT-OFF
DATES