Walker v. County of Santa Clara et al

Filing 155

STIPULATION AND ORDER RE 154 FOR REVISED BRIEFING SCHEDULE FOR HEARING ON PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION AS MODIFIED BY THE COURT. Motion Hearing set for 5/2/2013 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 3/5/13. (cl, COURT STAFF) (Filed on 3/5/2013)

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LORI E. PEGG, Acting County Counsel (S.B. #129073)
GREGORY J. SEBASTINELLI, Deputy County Counsel (S.B. #104884)
JOHN L. WINCHESTER, III, Deputy County Counsel (S.B. #142175)
OFFICE OF THE COUNTY COUNSEL
70 West Hedding Street, East Wing, Ninth Floor
San Jose, California 95110-1770
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
COUNTY OF SANTA CLARA and its SANTA
CLARA VALLEY MEDICAL CENTER,
HOLLISTER BREWSTER, M.D., ALFONSO
BANUELOS, M.D., and PETER GREGOR, M.D.

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
(San Francisco)

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GEETA SINGH, M.D.,

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Plaintiff,

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10-CV-04668 RS

STIPULATION AND ORDER FOR
REVISED BRIEFING SCHEDULE FOR
HEARING ON PLAINTIFF’S MOTION
FOR PRELIMINARY INJUNCTION
AS MODIFIED BY THE COURT

v.

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No.

COUNTY OF SANTA CLARA et al.,
Defendants.

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The parties, through their respective counsel of record, hereby stipulate and agree to an order

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for a revised briefing schedule respecting the Motion for Preliminary Injunction filed by Plaintiff,

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Geeta Singh, M.D., on February 25, 2013.

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By way of background, consideration and granting of SCVMC clinical privileges has been

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and continues to be an evolving process and the forms, requirements, procedures, and protocols

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differ today from what they were in 2011. Given Plaintiff’s present assignment in the Division of

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Cardiology, she may request Active clinical privileges respecting inpatients and outpatients.

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SCVMC is processing Plaintiff’s request for Active clinical privileges. But to do so, SCVMC must

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follow today’s procedures and protocols.

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Stip and Order for Revised Briefing Schedule
For Hearing on Plaintiff’s Preliminary Injunction

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10-CV-04668 RS

Once Plaintiff completes certain requested clinical activities, the Privileges in Cardiology

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form is expected to be signed-off and submitted to the SCVMC Medical Staff Office (MSO) for its

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consideration. The MSO then submits the necessary paperwork to the Credentials Committee by

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March 20, 2013, for its consideration. The Credentials Committee then submits paperwork to the

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Medical Executive Committee (MEC) by March 28, 2013, for its consideration. The MEC then

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submits paperwork to the Health & Hospital Committee of the Santa Clara County Board of

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Supervisors (BOS) for final consideration on April 10, 2013. The BOS is the governing board for

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the Santa Clara Valley Health & Hospital System and delegated authority and decision-making for

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clinical privileges to its Health & Hospital Committee. Whether Plaintiff’s requested Active clinical

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privileges are renewed will be known by April 10, 2013.

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The parties do not believe it is productive or efficient to maintain the present briefing

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schedule (opposition papers filed by March 20, reply papers filed by March 27, 2013, and a hearing

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on April 3, 2013) when the process will not be completed before April 10, 2013.
Accordingly, the parties stipulate and agree to an order for a revised briefing schedule. If a

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need exists as of April 10, 2013 for Plaintiff to pursue her motion, then opposition papers shall be

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filed by April 18, 2013 asserting all factual, legal, and administrative defenses, reply papers shall be

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filed by April 25, 2013, and then a hearing shall be held on the Court’s next regularly scheduled day
1:30 p.m.
for hearing motions - Thursday, May 2, 2013, at 10:00 a.m.

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Stip and Order for Revised Briefing Schedule
For Hearing on Plaintiff’s Preliminary Injunction

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10-CV-04668 RS

I hereby attest that I have on file all holograph signatures for any signatures indicated by a

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“conformed” signature (/S/) within this efiled document.
LORI E. PEGG
ACTING COUNTY COUNSEL

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/S/
GREGORY J. SEBASTINELLI
Deputy County Counsel

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Attorneys for County Defendants

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Dated: March 1, 2013

By:

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LAW OFFICES OF BONNER & BONNER

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Dated: March 1, 2013

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By:

/S/
CHARLES BONNER, ESQ.

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Attorneys for Plaintiff
GEETA SINGH, M.D.

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ORDER

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IT IS SO ORDERED. The briefing schedule respecting the Motion for Preliminary

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Injunction filed by Plaintiff, Geeta Singh, M.D., on February 25, 2013, is hereby revised. If a need

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exists as of April 10, 2013 for Plaintiff to pursue her motion, then opposition papers shall be filed by

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April 18, 2013, reply papers shall be filed by April 25, 2013, and then a hearing shall be held on the
1:30 p.m.
21 Court’s next regularly scheduled day for hearing motions - Thursday, May 2, 2013, at 10:00 a.m.
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3/5/13
Dated: _______________

_____________________________________
RICHARD SEEBORG
United States District Judge

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715352.DOC

Stip and Order for Revised Briefing Schedule
For Hearing on Plaintiff’s Preliminary Injunction

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10-CV-04668 RS