Camino Bell v. John Muir Health et al
Filing
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STIPULATION AND ORDER 29 REGARDING CONTINUANCE OF FACT DISCOVERY DEADLINE TO DECEMBER 5, 2016 AND EXPERT DISCOVERY DEADLINE TO JANUARY 13, 2017. Signed by Judge Richard Seeborg on 10/5/16. (cl, COURT STAFF) (Filed on 10/5/2016)
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JAMES R. ROSEN (SBN: 119438)
JROSEN@ROSENSABA.COM
ELIZABETH L. BRADLEY (SBN: 172272)
EBRADLEY@ROSENSABA.COM
ROSEN SABA LLP
9350 Wilshire Blvd. Suite 250
Beverly Hills, CA 90212
Telephone: (310) 285-1727
Facsimile: (310) 285-1728
Attorneys for Plaintiffs
CAMINO BELL
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MICHAEL D. BRUNO (SBN: 166805)
MBRUNO@GORDONREES.COM
HIEU TRAN (SBN: 280585)
HTRAN@GORDONREES.COM
GORDON REES SCULLY MANSUKHANI LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: (415) 986-5900
Facsimile: (415) 986-8054
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Attorneys for Defendant
JOHN MUIR HEALTH, ANGELA PERCIVAL and
SARA MONAHAN
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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CAMINO BELL, an individual,
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Plaintiff,
vs.
JOHN MUIR HEALTH, a California
corporation, JOHN MUIR MEDICAL
CENTER, an unknown business entity, and
DOES 1-20, et al
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Defendants.
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CASE NO. 15-CV-04564 - RS
STIPULATION AND [PROPOSED]
ORDER REGARDING CONTINUANCE
OF FACT DISCOVERY DEADLINE TO
DECEMBER 5, 2016 AND EXPERT
DISCOVERY DEADLINE TO
JANUARY 13, 2017
Hon. Judge Richard Seeborg
Complaint Filed: October 2, 2015
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STIPULATION AND [PROPOSED] ORDER REGARDING CONTINUANCE OF FACT DISCOVERY
DEADLINE TO DECEMBER 5, 2016 AND EXPERT DISCOVERY DEADLINE TO
JANUARY 13, 2017 - CASE NO. 15-CV-04564 - RS
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STIPULATION
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Pursuant to the Case Management Conference held on September 1, 2016, and the Civil
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Local Rule 7-12, the Plaintiff Camino Bell and Defendants John Muir Health, Angela Percival,
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and Sara Monahan (hereafter collectively referred to as “the Parties”), through their attorneys of
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record, hereby jointly stipulate and request a continuance of the current fact discovery deadline
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of November 4, 2016 to December 5, 2016, and the current deadline to disclose expert
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disclosures of December 16, 2016 to January 13, 2017 based on the good cause set forth below.
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Plaintiff’s Complaint was filed on October 2, 2015 in the above-entitled court. A case
management conference was held on September 1, 2016. See Docket #1. The case was referred
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to Magistrate Judge Joseph C. Spero for settlement purposes. See Docket #27. A Settlement
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Conference is scheduled for November 3, 2016. See Docket #28. The discovery cut-off
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deadline in the case is November 4, 2016. See Docket #21. The current deadline to exchange
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expert disclosures in the case is December 16, 2016. See Docket #21. The trial date for this
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action is presently set for May 8, 2017. See Docket #21.
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The parties believe that a brief continuance of the discovery deadlines will allow the
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parties to participate meaningfully in settlement negotiations at the upcoming settlement
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conference scheduled for November 3, 2016, while still allowing time for the parties to complete
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fact discovery and exchange expert disclosures prior to the proposed deadlines.
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STIPULATION AND [PROPOSED] ORDER REGARDING CONTINUANCE OF FACT DISCOVERY
DEADLINE TO DECEMBER 5, 2016 AND EXPERT DISCOVERY DEADLINE TO
JANUARY 13, 2017 - CASE NO. 15-CV-04564 - RS
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Subject to the approval of this Court, the parties have agreed to continue the fact
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discovery deadline from November 4, 2016 to December 5, 2016 and the current deadline to
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exchange expert disclosures be continued from December 16, 2016 to January 13, 2017. The
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parties have also agreed to set a deposition schedule in good faith in the event that mediation is
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unsuccessful.
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Dated: October 5, 2016
GORDON REES SCULLY MANSUKHANI LLP
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By:
____/S/ Hieu Tran________________
MICHAEL D. BRUNO
HIEU TRAN
Attorneys for Defendants
JOHN MUIR HEALTH, ANGELA PERCIVAL, SARA
MONAHAN
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Dated: October 5, 2016
ROSEN SABA LLP
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By:
___/S/ James R. Rosen_____________
JAMES R. ROSEN
ELIZABETH L. BRADLEY
Attorneys for Plaintiff
CAMINO BELL
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[PROPOSED] ORDER
Having considered the Parties’ Joint Stipulation to Continue the Fact Discovery Deadline,
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as well as the Court’s schedule, the Court hereby continues fact discovery deadline to December
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5, 2016 and the deadline to exchange expert disclosures to January 13, 2017 as requested.
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: 10/5/16
_________________________
RICHARD SEEBORG
United States District Judge
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1108541/29603689v.1
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STIPULATION AND [PROPOSED] ORDER REGARDING CONTINUANCE OF FACT DISCOVERY
DEADLINE TO DECEMBER 5, 2016 AND EXPERT DISCOVERY DEADLINE TO
JANUARY 13, 2017 - CASE NO. 15-CV-04564 - RS
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