Camino Bell v. John Muir Health et al

Filing 31

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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1 2 3 4 5 6 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 7 8 9 10 11 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 12 13 Attorneys for Defendant JOHN MUIR HEALTH, ANGELA PERCIVAL and SARA MONAHAN 14 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 18 CAMINO BELL, an individual, 19 20 21 22 Plaintiff, vs. JOHN MUIR HEALTH, a California corporation, JOHN MUIR MEDICAL CENTER, an unknown business entity, and DOES 1-20, et al 23 Defendants. 24 ) ) ) ) ) ) ) ) ) ) ) ) ) ) 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 25 26 /// 27 /// 28 1 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 1 STIPULATION 2 Pursuant to the Case Management Conference held on September 1, 2016, and the Civil 3 Local Rule 7-12, the Plaintiff Camino Bell and Defendants John Muir Health, Angela Percival, 4 and Sara Monahan (hereafter collectively referred to as “the Parties”), through their attorneys of 5 record, hereby jointly stipulate and request a continuance of the current fact discovery deadline 6 of November 4, 2016 to December 5, 2016, and the current deadline to disclose expert 7 disclosures of December 16, 2016 to January 13, 2017 based on the good cause set forth below. 8 9 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 10 to Magistrate Judge Joseph C. Spero for settlement purposes. See Docket #27. A Settlement 11 Conference is scheduled for November 3, 2016. See Docket #28. The discovery cut-off 12 deadline in the case is November 4, 2016. See Docket #21. The current deadline to exchange 13 expert disclosures in the case is December 16, 2016. See Docket #21. The trial date for this 14 action is presently set for May 8, 2017. See Docket #21. 15 The parties believe that a brief continuance of the discovery deadlines will allow the 16 parties to participate meaningfully in settlement negotiations at the upcoming settlement 17 conference scheduled for November 3, 2016, while still allowing time for the parties to complete 18 fact discovery and exchange expert disclosures prior to the proposed deadlines. 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 2 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 1 Subject to the approval of this Court, the parties have agreed to continue the fact 2 discovery deadline from November 4, 2016 to December 5, 2016 and the current deadline to 3 exchange expert disclosures be continued from December 16, 2016 to January 13, 2017. The 4 parties have also agreed to set a deposition schedule in good faith in the event that mediation is 5 unsuccessful. 6 7 Dated: October 5, 2016 GORDON REES SCULLY MANSUKHANI LLP 8 9 By: ____/S/ Hieu Tran________________ MICHAEL D. BRUNO HIEU TRAN Attorneys for Defendants JOHN MUIR HEALTH, ANGELA PERCIVAL, SARA MONAHAN 10 11 12 13 Dated: October 5, 2016 ROSEN SABA LLP 14 15 By: ___/S/ James R. Rosen_____________ JAMES R. ROSEN ELIZABETH L. BRADLEY Attorneys for Plaintiff CAMINO BELL 16 17 18 19 20 [PROPOSED] ORDER Having considered the Parties’ Joint Stipulation to Continue the Fact Discovery Deadline, 21 as well as the Court’s schedule, the Court hereby continues fact discovery deadline to December 22 5, 2016 and the deadline to exchange expert disclosures to January 13, 2017 as requested. 23 24 25 PURSUANT TO STIPULATION, IT IS SO ORDERED. Dated: 10/5/16 _________________________ RICHARD SEEBORG United States District Judge 26 27 28 1108541/29603689v.1 3 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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