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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SHAW VALENZA LLP
D. Gregory Valenza, Bar No. 161250
[e-mail]
Timothy L. Reed, Bar No. 258034
[e-mail]
300 Montgomery Street, Suite 788
San Francisco, California 94104
Telephone:
[phone]
Facsimile:
[phone]
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
[e-mail]
1001 Santa Clara Avenue, Suite A
Alameda, CA 94105
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiffs
Monique Matthews, Gabriel Oghwe, and Cynthia
Joiner

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MONIQUE MATTHEWS, an individual,
GABRIEL OGHWE, an individual, and
CYNTHIA JOYNER, an individual,
Plaintiffs,

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STIPULATION AND [PROPOSED]
ORDER TO CONTINUE MEDIATION
COMPLETION DATE

v.

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Case No. CV 10-04371 BZ

MEDICAL HILL REHAB CENTER,
L.L.C., a corporation, KINDRED
HEALTHCARE OPERATING, INC., a
corporation,

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Defendants.
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The Parties hereto, Defendants MEDICAL HILL REHAB CENTER, L.L.C. and

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KINDRED HEALTHCARE OPERATING, INC. ("Defendants"), and Plaintiffs MONIQUE

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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

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undersigned counsel, hereby stipulated and agree to this request for an order continuing the

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mediation completion date for this matter:

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1.

On April 18, 2011, the Court issued its Order Scheduling Jury Trial and Pretrial

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Matters. In that Order, the Court directed the Parties to conduct a mediation within 90 days, if

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possible. Accordingly, the mediation was to be completed by July 17, 2011.

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2.

The Parties originally scheduled mediation with Barbara S. Bryant, Esq. for

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July 13, 2011. However, due to scheduling conflicts and despite diligent efforts, the Parties and

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the Mediator agreed to continue the mediation to August 16, 2011.

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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:

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Dated: August 10, 2011
SHAW VALENZA LLP

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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.

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Dated: August 10, 2011

REVELATION LAW FIRM, P.C.

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By: /s/Melanie Popper
Melanie Popper
Attorneys for Plaintiffs
Monique Matthews, Gabriel Oghwe and
Cynthia Joiner

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186718.1.00133.038

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

-2-

STIPULATION AND [PROPOSED] ORDER TO
CONTINUE MEDIATION COMPLETION DATE

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ORDER

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Pursuant to the Parties’ Stipulation, and GOOD CAUSE APPEARING therefore:

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IT IS HEREBY ORDERED that the mediation completion date in this matter be and is

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hereby CONTINUED to August 16, 2011.

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August 15
DATED: _______________, 2011
Bernard Zimmerman
United States Magistrate Judge

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186720.1.00133.038

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

STIPULATION AND [PROPOSED] ORDER TO
CONTINUE MEDIATION COMPLETION DATE