Fortson v. Marriott International Inc.

Filing 52

STIPULATION AND ORDER FOR INDEPENDENT MEDICAL EXAMINATION PURSUANT TO RULE 35 OF THE FEDERAL RULES OF CIVIL PROCEDURE. Signed by Magistrate Judge Laurel Beeler on 1/14/2013. (ls, COURT STAFF) (Filed on 1/14/2013)

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Lake Merritt Plaza
1999 Harrison Street, Suite 2600
Oakland, CA 94612 -3541

LOMBARDI, LOPER & CO

NANT, LLP

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ANDREW J. SOMMER, State Bar No. 192844
KARA M. MACIEL, Admitted Pro Hac Vice
EPSTEIN BECKER & GREEN, P.C.
One California Street, 26th Floor
San Francisco, CA 94111-5427
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]
MATTHEW S. CONANT, State Bar No. 94920
MARIA M. LAMPASONA, State Bar No. 259675
LOMBARDI, LOPER & CONANT, LLP
Lake Merritt Plaza
1999 Harrison Street, Suite 2600
Oakland, CA 94612-3541
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]
Attorneys for Defendant
MARRIOTT INTERNATIONAL, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JAYNE FORTSON, an individual,
Plaintiff,

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v.

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MARRIOTT INTERNATIONAL, INC.,
a Delaware corporation, and DOES 1-50,

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Case No. 4:11-cv-01454 YGR
STIPULATION TO INDEPENDENT
MEDICAL EXAMINATION PURSUANT
TO RULE 35 OF THE FEDERAL RULES
OF CIVIL PROCEDURE : ORDER

Defendants.

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IT IS HEREBY STIPULATED by and between plaintiff JAYNE FORTSON (“Plaintiff”)
and defendant MARRIOTT INTERNATIONAL, INC. (“Defendant”), through their designated
counsel, that following the death of Dr. Kevin Harrington, plaintiff JAYNE FORTSON will
undergo a second physical examination pursuant to Rule 35 of the Federal Rules of Civil
Procedure. Said examination shall take place at a time and place mutually agreed upon by the
parties.

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Case No. 4:11-cv-01454 YGR

STIPULATION TO INDEPENDENT MEDICAL EXAMINATION

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This examination will be conducted for the purpose of determining the nature and extent

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of plaintiff's physical injuries and the relationship thereof to the accident which is the subject of

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this litigation, and will consist of all necessary and customary activities required to make such a

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determination, including but not limited to medical history, history of accident in question, and

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physical examination and evaluation. Photographs of plaintiff's injuries may be taken for use at

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trial.

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Dated: January 11, 2013

BROWNSTEIN THOMAS, LLP
By: /s/ Mark C. Thomas
MARK C. THOMAS
Attorneys for Plaintiff
JAYNE FORTSON

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Lake Merritt Plaza
1999 Harrison Street, Suite 2600
Oakland, CA 94612 -3541

LOMBARDI, LOPER & CO

NANT, LLP

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LOMBARDI, LOPER & CONANT, LLP

Dated: January 11, 2013

By: /s/ Maria M. Lampasona
MARIA M. LAMPASONA
Attorneys for Defendant
MARRIOTT INTERNATIONAL, INC.

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IT IS SO ORDERED.
2013
January 14,
Dated: __________, 2012

____________________________________
HON. LAUREL BEELER
UNITED STATES MAGISTRATE JUDGE

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Case No. 4:11-cv-01454 YGR

STIPULATION TO INDEPENDENT MEDICAL EXAMINATION