Fowler v. Kindred Healthcare Operating, Inc. et al

Filing 14

ORDER re 13 Stipulation filed by Kindred Healthcare Operating, Inc., Care Center of Rossmoor. Case Management Statement due by 1/31/2012. Initial Case Management Conference set for 2/7/2012 10:00 AM in Courtroom E, 15th Floor, San Francisco. Signed by Magistrate Judge Elizabeth D. Laporte on 12/7/2011. (hlk, COURT STAFF) (Filed on 12/7/2011)

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SHAW VALENZA LLP
D. Gregory Valenza, Bar No. 161250
[e-mail]
Amy K. Lee, Bar No. 244542
[e-mail]
300 Montgomery Street, Suite 788
San Francisco, California 94104
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants
Kindred Healthcare Operating, Inc. and Care Center
of Rossmoor, LLC dba Kindred Transitional Care
and Rehabilitation - Walnut Creek

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Jeremy Pasternak, Bar No. 181618
Anthony Oceguera, Bar No. 259117
LAW OFFICES OF JEREMY PASTERNAK
A Professional Corporation
445 Bush Street, Sixth Floor
San Francisco, California94108
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiff Laura Fowler

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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LAURA FOWLER,
Plaintiff,

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v.
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KINDRED HEALTHCARE
OPERATING, INC., a Delaware
Corporation; KINDRED HEALTHCARE
OPERATING, INC., a Delaware
Corporation doing business as CARE
CENTER OF ROSSMOOR; CARE
CENTER OF ROSSMOOR; a business
entity, form unknown; and Does 1 - 20,

Case No. CV 11-04600 EDL
STIPULATION AND [PROPOSED]
ORDER CONTINUING INITIAL CASE
MANAGEMENT CONFERENCE
[N.D. Cal. L. R. 7-12; 16-2(e)]
Magistrate Judge Elizabeth D. Laporte
Courtroom: E

Defendants.

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

STIPULATION AND [PROPOSED] ORDER
CONTINUING INITIAL CASE MANAGEMENT
CONFERENCE

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Plaintiff LAURA FOWLER ("Plaintiff") and Defendants KINDRED HEALTHCARE

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OPERATING, INC. and CARE CENTER OF ROSSMOOR, LLC DBA KINDRED

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TRANSITIONAL CARE AND REHABILITATION - WALNUT CREEK ("Defendants"), by

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and between their respective attorneys of record, hereby stipulate as follows:

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1.

Lead trial counsel, D. Gregory Valenza, Esq., is scheduled to begin a jury trial in

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Sacramento County Superior Court on JANUARY 3, 2012. The trial already has commenced

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(motions in limine have been decided, the courtroom is reserved, etc.), so this date is a firm trial

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date.

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2.

This Court's Order Setting Initial Case Management Conference and ADR

Deadlines scheduled the Initial Case Management Conference on JANUARY 3, 2012.
3.

The Standing Order re Case Management Conference of Courtroom E requires the

lead trial counsel to attend the case management conference.
4.

A brief continuance of the Initial Case Management Conference to either

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FEBRUARY 7 or 21, 2012 is necessary because lead trial counsel, D. Gregory Valenza, will not

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be able to attend the scheduled case management conference as he is scheduled to begin trial on

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the same date.

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5.

Pursuant to Local Rules 7-12 and 16-2(e), the parties agree to a continuance of the

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Initial Case Management Conference to either FEBRUARY 7 or 21, 2012, or as soon thereafter

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as compatible with this Court's case management calendar.

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6.

Pursuant to this Court's Order Setting Initial Case Management Conference and

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ADR Deadlines, all other deadlines, including Initial Disclosures and Joint Case Management

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Statement, will be continued accordingly.

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER
CONTINUING INITIAL CASE MANAGEMENT
CONFERENCE

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SO STIPULATED:

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Dated: December 7, 2011

Respectfully submitted,

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SHAW VALENZA LLP

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By: s/D. Gregory Valenza
D. Gregory Valenza
Amy K. Lee
Attorneys for Defendants
Kindred Healthcare Operating, Inc. and
Care Center of Rossmoor, LLC dba
Kindred Transitional Care and
Rehabilitation - Walnut Creek

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Dated: December 7, 2011

Respectfully submitted,
LAW OFFICES OF JEREMY PASTERNAK

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By: s/Anthony Oceguera
Jeremy Pasternak
Anthony Oceguera
Attorneys for Plaintiff
Laura Fowler

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER
CONTINUING INITIAL CASE MANAGEMENT
CONFERENCE

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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 Initial Case Management Conference in this matter

Joint Case Management Statement, are continued accordingly.

UNIT
ED

December 7
DATED: __________________ 2011

___________________________________
RED
ELIZABETHO ORDE
D. LAPORTE
IS S
I States Magistrate Judge
UnitedT

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.
zabeth D
udge Eli
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S DISTRICT
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Laporte

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IT IS FURTHER ORDERED that all deadlines, including those for Initial Disclosures and

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February 7
be and is hereby CONTINUED to ________________, 2012, at 10:00 a.m.

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER
CONTINUING INITIAL CASE MANAGEMENT
CONFERENCE