Alameda County Medical Center v. Johnson

Filing 5

STIPULATION AND ORDER EXTENDING TIME TO ANSWER re 4 Stipulation filed by Alameda County Medical Center, Charles E. Johnson. Signed by Judge Edward M. Chen on 1/4/10. (bpf, COURT STAFF) (Filed on 1/4/2010)

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JOSEPH P. RUSSONIELLO (CSBN 44332) United States Attorney JOANN M. SWANSON (CSBN 88143) Chief, Civil Division SHEILA LIEBER Deputy Branch Director JOSHUA WILKENFELD Trial Attorney United States Department of Justice, Civil Division Federal Programs Branch 20 Massachusetts Avenue NW Washington, DC 20530 [phone] [phone] (fax) [e-mail] Attorneys for Defendant UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) ) ) ) Plaintiff, ) ) v. ) KATHLEEN SEBELIUS, as Secretary of ) the United States Department of Health and ) ) Human Services, ) ) Defendant. ) ALAMEDA COUNTY MEDICAL CENTER, a California Public Hospital Authority, No. C 09-5062 EMC STIPULATION

IT IS HEREBY STIPULATED, pursuant to Civil L.R. 6-1(a), by and between the parties hereto, through their undersigned counsel, that Defendant's time to answer or otherwise respond to the Complaint is extended to March 16, 2010. In order to prepare its response to the complaint, Defendant must compile the administrative record--a process that requires an extensive amount of coordination and organization of records. Although Defendant is

[STIPULATION] No. C 09-5062 EMC

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expeditiously compiling this record, Defendant requires additional time to do so accurately and prepare a response to the complaint thereafter. The parties also stipulate that, pursuant to Fed. R. Civ. P. 25(d), the current Secretary of Health and Human Services, Kathleen Sebelius, is automatically substituted as the Defendant herein. This stipulation will not alter the date of any event or any deadline already fixed by Court order. \\ \\

DATED: December 31, 2009

Respectfully submitted, JOSEPH P. RUSSONIELLO United States Attorney JOANN M. SWANSON (CSBN 88143) Chief, Civil Division SHEILA LIEBER Deputy Branch Director

/s/ Joshua Wilkenfeld JOSHUA WILKENFELD Trial Attorney Attorneys for Defendant

DATED: December 31, 2009

STEPHENSON, ACQUISTO & COLMAN

/s/ Viola Rita Brown VIOLA RITA BROWN Attorneys for Plaintiffs
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