Medical Development International v. Sillen et al
Filing
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STIPULATION AND ORDER Continuing Case Management Conference to 8/22/2011 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 05/16/2011. (tmi, COURT STAFF) (Filed on 5/17/2011)
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M. THERESA TOLENTINO MEEHAN – SBN 204112
meehant@gtlaw.com
JEREMY A. MEIER – SBN 139849
meierj@gtlaw.com
RAY A. SARDO – SBN 245421
sardor@gtlaw.com
GREENBERG TRAURIG, LLP
1201 K Street, Suite 1100
Sacramento, CA 95814-3938
Telephone: (916) 442-1111
Facsimile: (916) 448-1709
Attorneys for Plaintiff and Counter-Defendant
Medical Development International
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO
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MEDICAL DEVELOPMENT
INTERNATIONAL, a Delaware corporation,
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Plaintiff,
v.
Defendants.
J. CLARK KELSO, in his capacity as receiver,
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STIPULATION FOR ORDER AND
[PROPOSED] ORDER CONTINUING
CASE MANAGEMENT CONFERENCE
SCHEDULED FOR JUNE 6, 2011 UNTIL
A DATE AFTER AUGUST 15, 2011
THE CALIFORNIA DEPARTMENT OF
CORRECTIONS AND REHABILITATION;
J. CLARK KELSO, in his capacity as receiver;
and DOES 1 – 20, inclusive,
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CASE NO. 3:10-cv-00443-TEH
Counter-claimant,
v.
MEDICAL DEVELOPMENT
INTERNATIONAL, a Delaware corporation,
Counter-defendant.
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Case No. 3:10-cv-00443-TEH
STIPULATION FOR ORDER AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT
CONFERENCE
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Pursuant to Civil L.R. 7-12 and 16-2(e) and Paragraph Four of this Court’s Standing
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Order, the parties, by and through their counsel, Greenberg Traurig for Plaintiff and Counter-
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defendant Medical Development International (“MDI”); Futterman Dupree Dodd Croley Maier
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LLP for Defendant and Counter-claimant J. Clark Kelso, in his capacity as the Receiver,
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(“Receiver”); and the California Office of the Attorney General for Defendant California
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Department of Corrections and Rehabilitation (“CDCR”), stipulate for an Order continuing the
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case management conference, currently set for June 6, 2011 to a date as convenient for the
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Court after August 15, 2011. This stipulation is based on the following facts:
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1.
The parties conducted an initial mediation session on February 14, 2011, and,
since that time, the parties have continued their negotiations through the mediator.
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CDCR has been working to present a further settlement offer to and has
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indicated it will be in a position to do so in the coming days. The parties have agreed to
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continue to work through the private mediator in an effort to try to resolve this matter in the
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next approximately 60-90 days.
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3.
The Court issued an Order on March 31, 2011, setting the case management
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conference in this case for June 6, 2011. Pursuant to that Order, the parties are presently
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required to file a joint case management statement on or before May 27, 2011.
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4.
On May 3, 2011, Greenberg Traurig, LLP substituted in as counsel for MDI.
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5.
The parties are seeking to continue the June 6, 2011 CMC as follows:
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a. Further mediation activities and settlement discussions, as anticipated by the
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parties, are expected to affect case management, scheduling and related issues;
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b. For reasons of judicial economy, so the court is not forced to spend valuable
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time addressing unnecessary case management issues;
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c. So that the Court and the parties are not forced to incur potentially unnecessary
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costs associated with conferring on a case management schedule, preparing case
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management statements, and appearing at related hearings; and
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d. To allow sufficient time for MDI’s new counsel to fully evaluate the case and
issues that might affect case management.
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Case No. 3:10-cv-00443-TEH
STIPULATION FOR ORDER AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT
CONFERENCE
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IT IS SO STIPULATED.
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Dated: May 16, 2011
GREENBERG TRAURIG, LLP
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By: /s/Jeremy A. Meier
M. Theresa Tolentino Meehan
Jeremy A. Meier
Ray A. Sardo
Attorneys for Plaintiff and
Counter-defendant
Medical Development International
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Dated: May 16, 2011
FUTTERMAN DUPREE DODD
CROLEY MAIER LLP
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By: /s/Martin Dodd
Jaime L. Dupree
Martin Dodd
Attorneys for Defendant and Counterclaimant
J. Clark Kelso, in his capacity as
Receiver
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Dated: May 16, 2011
KAMALA A. HARRIS
Attorney General Of California
By: /s/Michelle M. Mitchell
Michelle M. Mitchell
Deputy Attorney General
Attorneys for Defendant
California Department of Corrections
and Rehabilitation
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Case No. 3:10-cv-00443-TEH
STIPULATION FOR ORDER AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT
CONFERENCE
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[PROPOSED] ORDER
Based on the foregoing stipulation of the parties, it is hereby ORDERED that the case
management conference currently set for June 6, 2011, be and hereby is continued to
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August 22, 2011, at 1:30 PM. The parties shall file a joint case management conference
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statement on or before August 15, 2011.
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
ISTRIC
ES D
TC
AT
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Dated: 05/16/2011
________________________________
Honorable Thelton E. Henderson
United States District Court
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Case No. 3:10-cv-00443-TEH
STIPULATION FOR ORDER AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT
CONFERENCE
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