Matthews et al v. Medical Hill Rehab Center L.L.C. et al

Filing 12

STIPULATION AND ORDER GRANTING REQUEST TO CONTINUE MEDIATION COMPLETION DATE. Signed by Magistrate Judge Bernard Zimmerman on 8/15/2011. (bzsec, COURT STAFF) (Filed on 8/15/2011)

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1 2 3 4 5 6 7 8 9 10 11 12 13 SHAW VALENZA LLP D. Gregory Valenza, Bar No. 161250 gvalenza@shawvalenza.com Timothy L. Reed, Bar No. 258034 treed@shawvalenza.com 300 Montgomery Street, Suite 788 San Francisco, California 94104 Telephone: (415) 983-5960 Facsimile: (415) 983-5963 Attorneys for Defendants Medical Hill Rehab Center, L.L.C. and Kindred Healthcare Operating, Inc. THE REVALATION LAW FIRM, P.C. Melanie Popper, Bar No. 236279 mdp@revelationlaw.com 1001 Santa Clara Avenue, Suite A Alameda, CA 94105 Telephone: (510) 665-4195 Facsimile: (415) 665-4197 Attorneys for Plaintiffs Monique Matthews, Gabriel Oghwe, and Cynthia Joiner 14 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 18 19 MONIQUE MATTHEWS, an individual, GABRIEL OGHWE, an individual, and CYNTHIA JOYNER, an individual, Plaintiffs, 20 21 STIPULATION AND [PROPOSED] ORDER TO CONTINUE MEDIATION COMPLETION DATE v. 22 Case No. CV 10-04371 BZ MEDICAL HILL REHAB CENTER, L.L.C., a corporation, KINDRED HEALTHCARE OPERATING, INC., a corporation, 23 24 Defendants. 25 26 The Parties hereto, Defendants MEDICAL HILL REHAB CENTER, L.L.C. and 27 KINDRED HEALTHCARE OPERATING, INC. ("Defendants"), and Plaintiffs MONIQUE 28 MATTEWS, GABRIEL OGHWE and CYNTHIA JOINER ("Plaintiffs"), by and through their S HAW V ALENZA LLP ATTORNEYS AT LAW SAN FRANCISCO STIPULATION AND [PROPOSED] ORDER TO CONTINUE MEDIATION COMPLETION DATE 1 undersigned counsel, hereby stipulated and agree to this request for an order continuing the 2 mediation completion date for this matter: 3 1. On April 18, 2011, the Court issued its Order Scheduling Jury Trial and Pretrial 4 Matters. In that Order, the Court directed the Parties to conduct a mediation within 90 days, if 5 possible. Accordingly, the mediation was to be completed by July 17, 2011. 6 2. The Parties originally scheduled mediation with Barbara S. Bryant, Esq. for 7 July 13, 2011. However, due to scheduling conflicts and despite diligent efforts, the Parties and 8 the Mediator agreed to continue the mediation to August 16, 2011. 9 10 11 3. Therefore, the Parties jointly request the July 17, 2011 mediation completion date be continued until August 16, 2011, or as soon thereafter as otherwise possible. SO STIPULATED: 12 13 Dated: August 10, 2011 SHAW VALENZA LLP 14 15 By: /s/D. Gregory Valenza D. Gregory Valenza Timothy L. Reed Attorneys for Defendants Medical Hill Rehab Center, L.L.C. and Kindred Healthcare Operating, Inc. 16 17 18 19 20 Dated: August 10, 2011 REVELATION LAW FIRM, P.C. 21 22 By: /s/Melanie Popper Melanie Popper Attorneys for Plaintiffs Monique Matthews, Gabriel Oghwe and Cynthia Joiner 23 24 25 26 186718.1.00133.038 27 28 S HAW V ALENZA LLP ATTORNEYS AT LAW SAN FRANCISCO -2- STIPULATION AND [PROPOSED] ORDER TO CONTINUE MEDIATION COMPLETION DATE 1 ORDER 2 Pursuant to the Parties’ Stipulation, and GOOD CAUSE APPEARING therefore: 3 IT IS HEREBY ORDERED that the mediation completion date in this matter be and is 4 hereby CONTINUED to August 16, 2011. 5 6 7 August 15 DATED: _______________, 2011 Bernard Zimmerman United States Magistrate Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 186720.1.00133.038 28 S HAW V ALENZA LLP ATTORNEYS AT LAW SAN FRANCISCO STIPULATION AND [PROPOSED] ORDER TO CONTINUE MEDIATION COMPLETION DATE

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