California Nurses Association/National Nurses Organizing Committee v. California Pacific Medical Center

Filing 22

ORDER re 21 Stipulation, filed by California Nurses Association/National Nurses Organizing Committee, California Pacific Medical Center, Set/Reset Deadlines as to 21 Stipulation, 12 MOTION for Summary Judgment, 13 MOTION for Summary Judgment. CPMC'S responses due by 6/2/2009. CNA/NNOC replies due by 6/16/2009. Cross Motions Hearing set for 7/10/2009 10:00 AM. CPMC's cross-motion due by 6/2/2009.. Signed by Judge Charles R. Breyer on 5/19/09. (be, COURT STAFF) (Filed on 5/19/2009)

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F. Curt Kirschner (State Bar No. 122502) [e-mail] Christopher T. Scanlan (State Bar No. 211724) [e-mail] JONES DAY 555 California Street, 26th Floor San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant and Cross-Petitioner California Pacific Medical Center Donald W. Nielsen (State Bar No. 149002) [e-mail] Marcie Berman (State Bar No. 111043) [e-mail] Pamela Allen (State Bar No. 139136) [e-mail] CALIFORNIA NURSES ASSOCIATION/ NATIONAL NURSES ORGANIZING COMMITTEE LEGAL DEPARTMENT 2000 Franklin Street, Suite 300 Oakland, California 9412 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff and Cross-Respondent California Nurses Association/ National Nurses Organizing Committee

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

CALIFORNIA NURSES ASSOCIATION/NATIONAL NURSES ORGANIZING COMMITTEE, Plaintiff, v. CALIFORNIA PACIFIC MEDICAL CENTER, Defendants.

CASE NO. C09-01132 CRB STIPULATION AND [PROPOSED] ORDER SETTING BRIEFING SCHEDULE FOR PARTIES' SUMMARY JUDGMENT MOTIONS AND SETTING HEARING DATE FOR JULY 10, 2009, 10:00 A.M.

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STIP. AND [PROP.] RE: BRIEFING SCHEDULE, CASE NO. C09-01132

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CALIFORNIA PACIFIC MEDICAL CENTER, Cross-Petitioner, v. CALIFORNIA NURSES ASSOCIATION/NATIONAL NURSES ORGANIZING COMMITTEE, Cross-Respondents.

All parties to this action, through their duly authorized undersigned counsel, stipulate and request as follows: WHEREAS, Plaintiff/Cross-Respondent California Nurses Association/National Nurses Organizing Committee ("CNA/NNOC") filed its motion for summary judgment on May 7, 2009 and noticed the hearing for June 16, 2009; WHEREAS, Defendant/Cross-Petitioner California Pacific Medical Center ("CPMC")'s opposition to CNA/NNOC's motion must presently be filed by May 26, 2009 pursuant to Rule 73 of the Civil Local Rules of the Northern District of California; WHEREAS, this action has been reassigned to the undersigned Court since the filing of CNA/NNOC's motion; WHEREAS, in light of the reassignment of this action and CPMC's intention to file a cross-motion, the parties have determined that a coordinated briefing schedule would assist judicial economy and provide CPMC additional time needed to complete its summary judgment briefing; IT IS HEREBY STIPULATED that the parties will abide by the following briefing schedule with respect to the summary judgment motions: 1. CPMC shall file and serve its opposition to CNA/NNOC's motion for summary judgment and its cross-motion for summary judgment (with one combined brief) no later than June 2, 2009; 2
STIP. AND [PROP.] ORDER RE: BRIEFING SCHEDULE, CASE NO. C09-01132

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2. CNA/NNOC shall file and serve its opposition to CPMC's cross-motion and its reply in support of its motion for summary judgment (with one combined brief) no later than June 16, 2009; 3. CPMC may file a reply brief in support of its cross-motion for summary judgment no later than June 23, 2009; and 4. The hearing on both CNA/NNOC's motion for summary judgment and CPMC's cross-motion will be heard on July 10, 2009 at 10:00 a.m. Dated: May 14, 2009. Respectfully submitted, JONES DAY By: /s/ Christopher T. Scanlan Christopher T. Scanlan

Attorneys for Defendant and Cross-Petitioner CALIFORNIA PACIFIC MEDICAL CENTER Dated: May 14, 2009. Respectfully submitted, CALIFORNIA NURSES ASSOCIATION/NATIONAL NURSES ORGANIZING COMMITTEE LEGAL DEPARTMENT By: /s/ Donald W. Nielsen1

Attorneys for Plaintiff and Cross-Respondent CALIFORNIA NURSES ASSOCIATION/ NATIONAL NURSES ORGANIZING COMMITTEE IT IS SO ORDERED. Dated: _________, 2009. May 19

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er R. B ey Counsel electronically filing this stipulation represents that he hasaobtainedrthe consent Ch rles Ju all of undersigned opposing counsel to file this stipulation on behalf of dge parties. 3 STIP. AND [PROP.] ORDER RE: BRIEFING
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