Walker v. County of Santa Clara et al

Filing 79

STIPULATION AND ORDER TO FILE FOURTH AMENDED COMPLAINT. Signed by Judge Richard Seeborg on 11/21/11. (cl, COURT STAFF) (Filed on 11/21/2011)

*E-Filed 11/21/11*

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CHARLES A. BONNER, ESQ. SB# 85413
A. CABRAL BONNER, ESQ. SB# 247528
LAW OFFICES OF BONNER & BONNER
475 GATE FIVE RD. SUITE 212
SAUSALITO, CA 94965
TEL: [phone]
FAX: [phone]
[e-mail]
[e-mail]

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ATTORNEYS FOR PLAINTIFFS

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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THRESSA WALKER, GEETA SINGH,
M.D., AND KAI IHNKEN, M.D.,
Plaintiffs,
v.

No. 10-CV-04668 RS
STIPULATION TO FILE FOURTH
AMENDED COMPLAINT AND
[PROPOSED ORDER]
AS MODIFIED BY THE COURT

COUNTY OF SANTA CLARA, SANTA
CLARA VALLEY MEDICAL CENTER,
HOLLISTER BREWSTER, M.D.,
ALFONSO BANUELOS, M.D., DOLLY
GOEL, M.D., AND DOES 1 through 50,
inclusive,
Defendants.

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IT IS HEREBY STIPULATED AND AGREED by the parties, through their respective
attorneys of record, that the Court may grant Plaintiffs leave to file a Fourth Amended Complaint
to incorporate new allegations respecting events that took place after Plaintiffs filed their Third
Amended Complaint.
Plaintiffs contend that good cause exists for this further amended pleading incorporating

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new allegations that arise out of a common nucleus of operative facts as in Plaintiffs’ original and

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amended complaints. A copy of Plaintiff's proposed Fourth Amended Complaint is attached as
Stipulation to File Fourth Amended Complaint

10-CV-04668 RS

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A
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Exhibit A, and the new allegations are italicized and set forth in Paragraphs 120.1 through 120.55,
and 285 through 290.
It is further stipulated that Defendants shall have 30 days from the filing of the Fourth
Amended Complaint to respond to that Fourth Amended Complaint, and such response(s) need
only address those new allegations as identified in the above-referenced numbered paragraphs.
I hereby attest that I have on file all holograph signatures for any signatures indicated by a
"conformed" signature (/S/) within this efiled document.

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LAW OFFICES OF
BONNER & BONNER

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Dated: November 7, 2011

By:

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/S/
A.CABRAL BONNER

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Attorney for Plaintiffs

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MIGUEL MÁRQUEZ
County Counsel

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/S/
GREGORY J. SEBASTINELLI
Deputy County Counsel

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Attorneys for Defendants

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Dated: November 8, 2011

By:

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Stipulation to File Fourth Amended Complaint

10-CV-04668 RS

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[PROPOSED] ORDER
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IT IS HEREBY ORDERED that Plaintiffs may file a Fourth Amended Complaint in the
by December 12, 2011.
form attached hereto as Exhibit A. Defendants shall have 30 days from the filing of the Fourth
Amended Complaint to respond to it, and such response(s) need only address those new
allegations as identified in Paragraphs 120.1 to 120.55 and 285 to 290.

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11/21/11
Dated: ______________

________________________________
HONORABLE RICHARD SEEBORG
United States District Court Judge

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Stipulation to File Fourth Amended Complaint

10-CV-04668 RS

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