Wadsworth v. California Department of Corrections and Rehabilitation (CDCR) et al
Filing
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STIPULATION AND ORDER EXTENDING TIME TO RESPOND re 30 Stipulation filed by Christopher S. Wadsworth. Signed by Judge Edward M. Chen on 11/10/15. (bpf, COURT STAFF) (Filed on 11/10/2015)
Case 3:15-cv-02322-EMC Document 30 Filed 11/04/15 Page 1 of 4
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John F. Hyland (SBN 178875)
jhyland@rhdtlaw.com
Jessica Riggin (SBN 281712)
jriggin@rhdtlaw.com
RUKIN HYLAND DORIA & TINDALL LLP
100 Pine Street, Suite 2150
San Francisco, CA 94111
Telephone: (415) 421-1800
Facsimile: (415) 421-1700
Attorneys for Plaintiff
CHRISTOPHER WADSWORTH, M.D.
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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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CHRISTOPHER S. WADSWORTH, M.D.,
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Plaintiff,
v.
Case No. 3:15-cv-02322-EMC
STIPULATION TO EXTEND TIME TO
RESPOND AND ALLOW FILING OF
SECOND AMENDED COMPLAINT
JEFFREY BEARD; J. CLARK KELSO;
[Civil Local Rule 6-1(a)]
TIMOTHY BELAVICH; RACHEL CHEN;
COURTNEY CORRADO; EUREKA DAYE;
Date Action Filed: 5/22/2015
ANDREW DEEMS; ERIC MONTHEI; CHERA First Amended Complaint Filed: 6/3/2015
VAN BURG; LAURA WHYTE; and DOES 1
through 50, inclusive,
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Defendants.
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Pursuant to Local Rule 6-1(a), Plaintiff Christopher Wadsworth and Defendants Jeffrey
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Beard, Rachel Chen, Courtney Corrado, Chera Van Burg, Laura Whyte, and J. Clark Kelso
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(collectively referred to as “Stipulating Defendants”), through their respective counsel, hereby
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stipulate and agree as follows:
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WHEREAS, the current deadline for at least some of the Stipulating Defendants to respond
to the First Amended Complaint is November 4, 2015;
WHEREAS, Rukin Hyland Doria & Tindall LLP substituted into this case on October 30,
STIPULATION TO EXTEND TIME TO RESPOND AND ALLOW FILING OF SECOND AMENDED
COMPLAINT
Case No.: 3:15-cv-02322-EMC
Case 3:15-cv-02322-EMC Document 30 Filed 11/04/15 Page 2 of 4
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2015 as counsel of record for Plaintiff Wadsworth and intend to file on Plaintiff’s behalf a second
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amended complaint;
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WHEREAS, Rukin Hyland Doria & Tindall LLP require sufficient time to meet and confer
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with Stipulating Defendants’ counsel and to prepare an amended complaint given the voluminous
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facts and currently pled causes of action in the operative complaint;
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WHEREAS, Plaintiff intends to file the second amended complaint prior to the Case
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Management Conference currently scheduled for December 10, 2015, and therefore the extension
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of time for Plaintiff to file a second amended complaint will not unduly affect or interfere with any
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conferences or hearings scheduled currently on calendar in this matter;
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WHEREAS, it is Plaintiff’s and the Stipulating Defendants’ understanding that the
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remaining Defendants have not yet secured counsel but will not be prejudiced by this stipulation;
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WHEREAS, the parties execute this stipulation upon mutual agreement, in good faith, and
not for the purpose of causing unwarranted delay; and
WHEREAS, the parties have not previously stipulated for an extension of time for Plaintiff
to file an amended complaint;
The parties now stipulate that (1) Plaintiff shall file his second amended complaint on or
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before December 7, 2015, and (2) the Stipulating Defendants shall file their respective responsive
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pleadings thereto not later than January 11, 2015 and, by entering into this stipulation, shall not be
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deemed to have waived any defenses they have to the second amended complaint.
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IT IS SO STIPULATED.
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Dated: November 4, 2015
RUKIN HYLAND DORIA & TINDALL LLP
By:
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Jessica Riggin
John F. Hyland
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________/s/ Jessica Riggin___________
Counsel for Plaintiff Christopher Wadsworth, M.D.
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-1STIPULATION TO EXTEND TIME TO RESPOND AND ALLOW FILING OF SECOND AMENDED
COMPLAINT
Case No.: 3:15-cv-02322-EMC
Case 3:15-cv-02322-EMC Document 30 Filed 11/04/15 Page 3 of 4
Case 3:15-cv-02322-EMC Document 30 Filed 11/04/15 Page 4 of 4
ERED
R NIA
O ORD
IT IS S
. Chen
RT
A
H
ER
FO
NO
dward M
Judge E
LI
UNIT
ED
S
RT
U
O
IT IS SO ORDERED:
________________________
DISTRIC
TC
Edward M. Chen ES
T
TA Judge
U.S. District
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F
D IS T IC T O
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