Carr v. Beverly Health and Rehabilitation Services, Inc.

Filing 46

STIPULATION AND ORDER re 45 STIPULATION WITH PROPOSED ORDER CONTINUING CASE MANAGEMENT CONFERENCE filed by Andrew Carr Case Management Statement due by 7/18/2013. Case Management Conference set for 7/25/2013 09:00 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 6/24/13. (bpf, COURT STAFF) (Filed on 6/24/2013)

1 ALAN HARRIS (CA Bar No. 146079)
HARRIS & RUBLE
2 6424 Santa Monica Boulevard
Los Angeles, California 90038
[phone]
3 Telephone: [phone]
Facsimile:
4 DAVID S. HARRIS (CA Bar No. 215224)

5 NORTH BAY LAW GROUP #2
116 E. Blithedale Avenue, Suite
California 94941-2024
6 Mill Valley, [phone]
Telephone:

7 Facsimile: [phone]
8 Attorneys for Plaintiff
ANDREW CARR
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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13 ANDREW CARR, individually and on behalf
14 of all others similarly situated,

STIPULATION AND [PROPOSED]
ORDER CONTINUING CASE
MANAGEMENT CONFERENCE

Plaintiff,

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Case No.: 12-CV-02980-EMC

v.

Courtroom:
Judge:

AND
17 BEVERLY HEALTHSERVICES, INC.,
REHABILITATION

18 GOLDEN LIVINGCENTER - PETALUMA,
and DOES 1 to 50,
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Defendants.

5
Hon. Edward M. Chen

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-1STIPULATION AND [PROPOSED] ORDER CONTINUING
CASE MANAGEMENT CONFERENCE

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The parties hereby stipulate as follows:

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WHEREAS, on February 27, 2013, the parties engaged in private mediation with Mr.

3 Michael Loeb at JAMS in San Francisco. At that time, progress was made but the parties were
4 unable to settle the case. Since the mediation, the parties have continued to engage in additional
5 investigation and have exchanged supplemental documentation and information relevant to the
6 claims. To this end, the parties have made significant progress in narrowing the issues and are
7 working towards potential resolution of all matters set forth in this action.
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IT IS THEREFORE STIPULATED AND AGREED, in order to allow the parties
9 additional time to work towards settlement, and in order to avoid the time and expense of having
10 defense counsel fly to San Francisco for the Case Management Conference, the parties have
11 stipulated to continuing the Case Management Conference until July 25, 2013, at 9:00 a.m. in
12 Courtroom 5, 17th Floor, San Francisco, if that date is convenient to the Court. The parties shall
13 file a Joint Case Management Statement at least one week prior to the Case Management
14 Conference.
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IT IS SO STIPULATED.

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Respectfully submitted,

17 Date: June 20, 2013
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NORTH BAY LAW GROUP
By

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/s/
David S. Harris

Attorneys for Plaintiff
ANDREW CARR

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Date: June 20, 2013

DINSMORE & SHOHL LLP

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By

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/s/
Charles Roesch

Attorneys for Defendant
BEVERLY HEALTH AND
REHABILITATION SERVICES, INC.

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STIPULATION AND [PROPOSED] ORDER CONTINUING
CASE MANAGEMENT CONFERENCE

1 IT IS HEREBY ORDERED AS FOLLOWS:
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The Case Management Conference is continued to July 25, 2013, at 9:00 a.m. in
3 Courtroom 5. The parties shall file a Joint Case Management Statement at least one week prior to
S DISTRICT
4 the Conference.
TE
__________________________________
VED
APPRO
Honorable Edward M. Chen
United States District Court Judge

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6 DATED: June __, 2013
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-3STIPULATION AND [PROPOSED] ORDER CONTINUING
CASE MANAGEMENT CONFERENCE

C