Carnes v. Atria Senior Living, Inc.

Filing 25

Order by Hon. Vince Chhabria granting 24 Stipulation Extending Time for Initial Disclosures and Submission of Discovery Plan.(knm, COURT STAFF) (Filed on 9/3/2014)

1 LEWIS BRISBOIS BISGAARD & SMITH LLP
REUBEN B. JACOBSON, SB# 167972
E-Mail: [e-mail]
2
333 Bush Street, Suite 1100
3 San Francisco, California 94104
Telephone: [phone]
4 Facsimile: 415.434.0882
5 LEWIS BRISBOIS BISGAARD & SMITH LLP
JEFFREY S. RANEN, SB# 224285
E-Mail: [e-mail]
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CHRIS CROCKETT, SB# 281388
E-Mail: [e-mail]
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221 North Figueroa Street, Suite 1200
8 Los Angeles, California 90012
Telephone: [phone]
9 Facsimile: 213.250.7900
10 Attorneys for Defendant, ATRIA SENIOR
LIVING, INC.
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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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16 THOMAS CARNES, by and through his
Guardian ad Litem, Juliana Christine Clegg,
17 on his own behalf and on behalf of others
similarly situated,
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Plaintiff,
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vs.
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ATRIA SENIOR LIVING, INC., and DOES 1
21 through 100,

CASE NO. 3:14-cv-02727-VC
STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME FOR
EXCHANGE OF INITIAL DISCLOSURES
AND SUBMISSION OF DISCOVERY
PLAN
Judge:
Trial Date:

Hon. Vince Chhabria
None Set

[Civil L.R. 6-1(a)]
Defendants.

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LEWIS

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

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Pursuant to Local Rule 6-1(a), the parties hereby provide notice of their stipulation to
extend the time for exchanging initial disclosures. Under Fed. R. Civ. P. 26(a)(1), the parties must
make their initial disclosures and submit a written report outlining their proposed discovery plan
within 14 days after holding their Rule 26(f) conference, “unless a different time is set by
4842-0581-2253.1

3:14-cv-02727-VC
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR EXCHANGE OF INITIAL DISCLOSURES
AND SUBMISSION OF DISCOVERY PLAN

1 stipulation or court order.” The parties held their Rule 26(f) conference on August 20, 2104, and
2 stipulated that they would make their initial disclosures and submit their proposed discovery plan
3 on September 17, 2014. This stipulation will not alter the date of any event or any deadline
4 already fixed by Court order.
5 IT IS SO STIPULATED.
6 DATED: August 27, 2014

LEWIS BRISBOIS BISGAARD & SMITH

LLP

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By:

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11 DATED: August 27, 2014

/s/ Jeffrey S. Ranen
Jeffrey S. Ranen
Attorneys for Defendant,
ATRIA SENIOR LIVING, INC.

STEBNER & ASSOCIATES

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By:
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/s/ Kathryn A. Stebner
Kathryn A. Stebner
Class Counsel for Plaintiffs,
THOMAS CARNES

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DECLARATION OF CONSENT
I, JEFFREY S. RANEN, hereby declare pursuant to General Order 45, § X(B), that I have

19 obtained concurrence in the filing of this document from Kathryn A. Stebner.
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I declare under penalty of perjury that the foregoing is true and correct.

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Executed on August 27, 2014, in the City of Los Angeles, California.

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By:

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/s/ Jeffrey S. Ranen
Jeffrey S. Ranen

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LEWIS

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

28
4842-0581-2253.1

3:14-cv-02727-VC
2
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR EXCHANGE OF INITIAL DISCLOSURES
AND SUBMISSION OF DISCOVERY PLAN

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[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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_________________
4 DATED: September 3, 2014
Honorable Vince Chhabria
United States District Judge

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LEWIS

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

28
4842-0581-2253.1

3:14-cv-02727-VC
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR EXCHANGE OF INITIAL DISCLOSURES
AND SUBMISSION OF DISCOVERY PLAN

1

UNITED STATES DISTRICT COURT PROOF OF SERVICE
Thomas Carnes v. Atria Senior Living, Inc.
CAND Case No.: 3:14-cv-02727-VC
Assigned to: The Hon. Vince Chhabria
Client/Matter: 27185.95

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4 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
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At the time of service, I was over 18 years of age and not a party to the action. My
business address is 221 North Figueroa Street, Suite 1200, Los Angeles, California 90012.

On August 27, 2014, I served the following document described as STIPULATION AND
7 [PROPOSED] ORDER TO EXTEND TIME FOR EXCHANGE OF INITIAL
DISCLOSURES AND SUBMISSION OF DISCOVERY PLAN on the following persons at the
8 following address:
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SEE ATTACHED LIST

10 BY ECF SYSTEM
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By filing the document(s) listed above on the Court’s Electronic Case Filing System, I am
informed and believe that the documents will be electronically served on all individuals registered
12 with such system. For individuals not registered with the ECF system, I have placed the
document(s) listed above in a sealed envelope with postage thereon fully prepaid, in the United
13 States mail at Los Angeles, California addressed as set forth below for delivery. I am readily
familiar with the firm’s practice of collection and processing of correspondence for mailing.
14 Under that practice, it would be deposited with the U.S. Postal Service on that same day with
postage thereon fully prepaid in the ordinary course of business.
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I declare under penalty of perjury under the laws of the State of California that the
16 foregoing is true and correct.
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Executed on August 27, 2014, at Los Angeles, California.

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/s/ Jeffrey S. Ranen
Jeffrey S. Ranen

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LEWIS

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

28
4842-0581-2253.1

3:14-cv-02727-VC
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR EXCHANGE OF INITIAL DISCLOSURES
AND SUBMISSION OF DISCOVERY PLAN

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SERVICE LIST
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Kathryn A. Stebner
3 STEBNER AND ASSOCIATES
870 Market Street, Suite 1212
4 San Francisco, CA 94102
[phone]
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Michael D. Thamer
6 LAW OFFICES OF MICHAEL D. THAMER
Old Callahan School House
7 12444 South Highway 3
Callahan, CA 96014-1568
8 [phone]

Via ECF System

Via U.S. Mail

9 Robert S. Arns
THE ARNS LAW FIRM
10 515 Folsom Street, 3rd Floor
San Francisco, CA 94105
11 [phone]

Via ECF System

12 Guy B. Wallace
SCHNEIDER WALLACE COTTRELL KONECKY LLP
13 180 Montgomery Street, Suite 2000
San Francisco, CA 94102
14 [phone]

Via ECF System

15 W. Timothy Needham
JANSSEN MALLOY LLP
16 730 Fifth Street
Eureka, CA 95501
17 [phone]

Via U.S. Mail

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LEWIS

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

28
4842-0581-2253.1

3:14-cv-02727-VC
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR EXCHANGE OF INITIAL DISCLOSURES
AND SUBMISSION OF DISCOVERY PLAN