Santa Rosa Memorial Hospital v. Sebelius et al

Filing 36

STIPULATION AND ORDER to Extend Defendant's Deadline to Respond to Amended Complaint and to Continue Initial Case Management Conference. Case Management Statement due by 4/10/2015. Case Management Conference set for 4/17/2015 10:00 AM in Courtroom 1, 17th Floor, San Francisco. Signed by Judge Samuel Conti on 01/26/2015. (tmi, COURT STAFF) (Filed on 1/26/2015)

1 MELINDA HAAG (CABN 132612)
United States Attorney
2 ALEX G. TSE (CABN 152348)
Chief, Civil Division
3 JENNIFER S WANG (CABN 233155)
Assistant United States Attorney
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450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
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Telephone: [phone]
FAX: [phone]
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[e-mail]
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Attorneys for Defendant
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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SANTA ROSA MEMORIAL HOSPITAL,
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)
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Plaintiff,
)
)
v.
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)
SYLVIA MATHEWS BURWELL, IN HER
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OFFICIAL CAPACITY AS SECRETARY OF )
HEALTH AND HUMAN SERVICES,
)
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Defendant.

CASE NO. C14-1345 SC
STIPULATION TO EXTEND DEFENDANT’S
DEADLINE TO RESPOND TO AMENDED
COMPLAINT AND TO CONTINUE INITIAL
CASE MANAGEMENT CONFERENCE

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Subject to the approval of the Court, defendant Sylvia Matthews Burwell and plaintiff Santa
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Rosa Memorial Hospital, by and through their respective counsel, hereby stipulate as follows:
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1. Plaintiff’s Complaint was filed on March 24, 2014. While the parties engaged in initial settlement
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discussions, the parties stipulated to extend defendant’s time to respond to the Complaint until
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October 30, 2014. On October 30, 2014, defendant filed a motion to dismiss under Federal Rule of
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Civil Procedure 12(b)(2) and 12(b)(6).
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2. On November 14, 2014, pursuant to stipulation by the parties, the Court ordered plaintiff to file an
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Amended Complaint in lieu of filing an opposition to defendant’s motion to dismiss by November
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20, 2014. The Court set January 30, 2015 as the deadline for defendant’s response to the Amended
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STIP. TO EXTEND DEADLINE TO RESPOND TO AM. COMPL & TO CONTINUE CMC
C14-1345 SC
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Complaint, and continued the initial case management conference to February 20, 2015 at 10:00 a.m.

2 3. Plaintiff filed its Amended Complaint on November 20, 2014.
3 4. The parties are currently engaged in settlement negotiations. To provide further time for those
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negotiations and to avoid potentially unnecessary litigation, the parties have stipulated to extend

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defendant’s deadline to respond to the Amended Complaint by sixty (60) days, from January 30,

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2015 until March 31, 2015. For the same reason and so that defendant’s responsive pleading is on

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file before the initial case management conference, the parties respectfully request that the initial

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case management conference currently set for February 20, 2015, at 10:00 a.m., be continued to

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April 17, 2015, at 10:00 a.m.

10 IT IS SO STIPULATED.
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Respectfully submitted,

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MELINDA HAAG
United States Attorney

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14 DATED: January 21, 2015
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16 DATED: January 21, 2015
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_/s/______________________
JENNIFER S WANG
Assistant United States Attorney
_/s/______________________
JASON T. LUNDY
POLSINELLI PC
Attorneys for Plaintiff,
Santa Rosa Memorial Hospital

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[PROPOSED] ORDER
Pursuant to the parties’ stipulation and good cause having been shown, it is ordered that defendant’s

22 response to the Amended Complaint is due on or before March 31, 2015. The initial case management
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conference is continued from February 20, 2015 to April 17, 2015 at 10:00 a.m., and the parties’ joint

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case management statement is due on or before April 10, 2015.
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S

R NIA

__________________________
HON. SAMUEL CONTI
onti
amuel C
Judge S
United States District Judge
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H

E

A

RT

FO

NO

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UNIT
ED

27 DATED:____________________
01/26/2015

S DISTRICT
TE
C
TA

RT
U
O

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IT IS SO ORDERED.

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STIP. TO EXTEND DEADLINE TO RESPOND TO AM. COMPL & TO CONTINUE CMC O F C
D IS T IC T
R
C14-1345 SC
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