Grotz v. Kaiser Foundation Hospitals et al

Filing 16

STIPULATION AND ORDER re #13 STIPULATION WITH PROPOSED ORDER FOR DISMISSAL AS TO THE PERMANENTE MEDICAL GROUP ONLY filed by Kaiser Foundation Hospitals, The Permanente Medical Group, Inc.. Signed by Judge Edward M. Chen on 8/29/12. (bpf, COURT STAFF) (Filed on 8/29/2012)

1 George F. Camerlengo (SBN 50232)
[e-mail]
2 CAMERLENGO & JOHNSON
643 Bair Island Road, Ste. 400
3 Redwood City, CA 94063
Tel. [phone]
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Fax [phone]
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Attorney for Plaintiff
6 KRISTINNA GROTZ
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Michele Ballard Miller (SBN 104198)
[e-mail]
Katherine L. Kettler (SBN 231586)
[e-mail]
MILLER LAW GROUP
A Professional Corporation
111 Sutter Street, Suite 700
San Francisco, CA 94104
Tel. [phone]
Fax [phone]

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Attorneys for Defendant
14 KAISER FOUNDATION HOSPITALS
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IN THE UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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19 KRISTINNA GROTZ, an individual,
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Plaintiff,

Case No.: CV 12 3539 JSC

STIPULATION AND [PROPOSED] ORDER
FOR DISMISSAL

v.

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23 KAISER FOUNDATION HOSPITALS, INC.,
THE PERMANENTE MEDICAL GROUP,
24 INC., SEIU-UNITED HEALTHCARE
WORKERS WEST,
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EMC

Complaint filed: July 6, 2012

Defendants.

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STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL
Case No.: CV 12 3539 JSC

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It is hereby stipulated by Plaintiff Kristinna Grotz (“Grotz”) and Defendant

2 Kaiser Foundation Hospitals (“KFH”), as follows:
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1.

Grotz will dismiss with prejudice TPMG as a named defendant in this

5 matter. Grotz and TPMG will bear their own fees and costs incurred in connection with this
6 dismissal.
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2.

KFH stipulates it was Grotz’s employer during all relevant times

9 alleged in the Complaint in this matter, and that TPMG was not Grotz’s employer during
10 any relevant times alleged in the complaint in this matter. During the pendency of this
11 action, neither Grotz nor KFH will assert otherwise.
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IT IS SO STIPULATED.

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15 Dated: August 24, 2012

CAMERLENGO & JOHNSON

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By:

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/S/
George F. Camerlengo
Attorney for Plaintiff
Kristinna Grotz

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20 Dated: August 24, 2012

MILLER LAW GROUP
A Professional Corporation

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By:

/S/
Michele B. Miller
Attorneys for Defendant
Kaiser Foundation Hospitals

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STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL
Case No.: CV 12 3539 JSC

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ORDER

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As stipulated and agreed to by Plaintiff Kristinna Grotz and Defendant Kaiser

4 Foundation Hospitals, defendant The Permanente Medical Group, Inc. is hereby dismissed
5 from this action with prejudice.
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dward
Judge E

RT

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AS MO

ER

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n

M. Che

A

H

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R NIA

DIFIE

FO

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4815-6485-6336, v. 1

_______________________________________
DERED
HONORABLE EDWARDR CHEN
SO O M. D
IT IS

LI

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8/29
Dated: ______________, 2012

UNIT
ED

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NO

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S DISTRICT
TE
C
TA

RT
U
O

S

7 IT IS SO ORDERED.

N

F
D IS T IC T O
R

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STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL
Case No.: CV 12 3539 JSC

C