Gregus v. Stryker

Filing 21

STIPULATION AND ORDER RE 20 CONTINUING CASE MANAGEMENT CONFERENCE. Case Management Conference set for 8/4/2011 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 5/24/11. (cl, COURT STAFF) (Filed on 5/25/2011)

*E-Filed 5/25/11*
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SEDGWICK LLP
Ralph Campillo (State Bar No. 70376)
Mario Horwitz (State Bar No. 110965)
James Nelson (State Bar No. 181256)
801 South Figueroa Street, 19th Floor
Los Angeles, CA 90017-5556
Telephone : [phone]
Facsimile: 213-426-6921
Email: ralph.campillo ,sedgwicklaw.com
mario.horwitzg sedgwicklaw.com
james.nelsong sedgwicklaw.com
Attorneys for Defendant, Stryker Corporation ( sued as
Stryker)

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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RICHARD GREGUS, an individual,

) CASE NO. 3:11-CV-00404-RS

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Plaintiff,
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V.
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STRYKER, a New Jersey Corporation and
DOES 1 to 50, inclusive,
Defendant.

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) JOINT STIPULATION TO CONTINUE
CASE MANAGEMENT CONFERENCE;
[PROPOSED] ORDER
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Plaintiff and defendant, by and through their counsel of record, hereby jointly request and
submit this stipulation to continue the case management conference as follows:

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WHEREAS the Court has scheduled a Case Management Conference for June 2, 2011 at
10:00 a.m.;

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WHEREAS Defendant filed a Motion to Dismiss Plaintiff's First Amended Complaint,
and the Court issued an Order dated April 27, 2011 granting Defendant's Motion with leave to
amend;

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WHEREAS Plaintiff intends to file a Second Amended Complaint on or before May 20,
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LA/1026777vl

-1JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

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2011;
WHEREAS Defendant's response to the forthcoming Second Amended Complaint will
not be due until the Case Management Conference on June 2, or shortly thereafter;
WHERAS the parties wish to conserve resources by allowing Defendant sufficient time

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to determine whether plaintiff's forthcoming Second Amended Complaint states a claim for

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relief that survives the statute of limitations bar, and any other related issues, as well as time for a

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hearing on any requested Court determination of legal issues that might be raised by the Second

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Amended Complaint;

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WHEREAS the parties are discussing the issues required for the Case Management
conference; and

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WHEREAS there have been no previous modifications of time in this case requested by
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the parties, and the parties do not anticipate this modification will have any significant impact on
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this case.
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NOW, THEREFORE, IT IS HEREBY STIPULATED:
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1. The Case Management Conference currently on calendar for June 2, 2011 shall be
continued to August 4, 2011.
DATED: May 2, 2011

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By:

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LAW OFFICES OF GENE SHIODA

DATED: May (q, 2011

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Gene Shioda
James Kim
Attorneys for Plaintiff

SEDGWICK LLP

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By: /s/ James Nelson
Ralph Campillo
Mario Horwitz
James Nelson
Attorneys for Defendant, Stryker Corporation

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LAl1026777v1

-2JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

[PROPOSEDI ORDER

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Pursuant to the stipulated request of the parties , the Court hereby orders that:

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1) The Case Management Conference currently on calendar for June 2 , 2011 shall be

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continued to August 4, 2011.

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Dated: May_, 2011

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HONORABLE RICHARD SEEBORG
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LA/1026777v1

-3JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER