Gary Martinovsky, et al v. County of Alameda et al

Filing 25

STIPULATED REQUEST FOR ORDER CHANGING TIME OF CASE MANAGEMENT CONFERENCE AND ORDER. The Case Management Conference currently set for April 22, 2016, is continued to July 1, 2016, at 10:30 a.m. Signed by Judge Maxine M. Chesney on April 13, 2016. (mmclc2, COURT STAFF) (Filed on 4/13/2016)

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Michael C. Wenzel, State Bar No. 215388
Talia B. Saypoff, State Bar No. 284704
BERTRAND, FOX, ELLIOT, OSMAN & WENZEL
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]
Attorneys for Defendants
COUNTY OF ALAMEDA, NANCY E. O’MALLEY,
JOHN PAUL WILLIAMS and EDDIE BERMUDEZ

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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GARY MARTINOVSKY, M.D., and
INTEGRATED PAIN CARE, INC.,
Plaintiffs,

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STIPULATED REQUEST FOR ORDER
CHANGING TIME OF CASE MANAGEMENT
CONFERENCE AND [PROPOSED] ORDER

v.

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Case No. 3:16-cv-00403-MMC

COUNTY OF ALAMEDA, DISTRICT
ATTORNEY NANCY E. O’MALLEY, in Her
Official and Individual Capacities, DA
INSPECTORS JOHN PAUL WILLIAMS and
EDDIE BERMUDEZ, CALIFORNIA
DEPARTMENT OF INSURANCE
DETECTIVE FERNANDO CUBANGBANG,
and DOES 1 to 20,

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Defendants.
Hon. Maxine M. Chesney

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Pursuant to United States District Court, Northern District of California Local rule 6-2 (a), and as

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supported by the Declaration of Talia Saypoff filed herewith, the parties through undersigned counsel

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hereby stipulate and respectfully request that the Court enlarge time for the Case Management

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Conference, currently set for April 22, 2016. The parties declare in support of this request:

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WHEREAS, on January 22, 2016 plaintiffs filed their original Complaint for damages;

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WHEREAS, on April 7, 2016 pursuant to an agreed-upon extension of time, defendants
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STIPULATED REQUEST FOR ORDER CHANGING TIME OF CASE MANAGEMENT CONFERENCE
Case No.: 3:16-cv-00403-MMC

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COUNTY OF ALAMEDA, NANCY E. O’MALLEY, JOHN PAUL WILLIAMS and EDDIE

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BERMUDEZ filed their Notice of Motion, Motion to Dismiss and Motion for More Definite Statement;

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WHEREAS, on April 8, 2016, defendant FERNANDO CUBANGBANG filed his Notice of
Motions, Motion to Dismiss, Motion for More Definite Statement and Request for Stay;

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WHEREAS, the hearing on all defendants’ Motions to Dismiss, Motions for More Definite
Statement and Request for Stay are set for May 20, 2016;

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WHEREAS, the Case Management Conference is set for April 22, 2016 and the Case
Management Statement and Initial Disclosures are due on April 14, 2016; and

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WHEREAS, the parties are in agreement that in the interest of judicial efficiency, the Case

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Management Conference should be continued to a date on or after the hearing on defendants’ Motions to

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Dismiss, Motions for More Definite Statement and Request for Stay.

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IT IS HEREBY STIPULATED AND AGREED, subject to court approval, by and between the
undersigned counsel on behalf of the parties as follows:

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Pursuant to Northern District Civil Local Rule 6-2, the April 22, 2016 Case Management
Conference is continued to a date on or after May 20, 2016;

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Dated: April 12, 2016

BERTRAND, FOX, ELLIOT, OSMAN & WENZEL

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By:

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/s/Talia Saypoff
Michael C. Wenzel
Talia B. Saypoff
Attorneys for Defendants

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COUNTY OF ALAMEDA, NANCY E. O’MALLEY,
JOHN PAUL WILLIAMS and EDDIE BERMUDEZ

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STIPULATED REQUEST FOR ORDER CHANGING TIME OF CASE MANAGEMENT CONFERENCE
Case No.: 3:16-cv-00403-MMC

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Dated: April 12, 2016

KAMALA D. HARRIS
Attorney General of California

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By:

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/s/ John Devine
John P. Devine
Supervising Deputy Attorney General
Attorneys for Defendant
FERNANDO CUBANGBANG

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Dated: April 12, 2016

THE LAW OFFICES OF JOHN BURTON

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By:

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/s/ John Burton
John Burton
Attorneys for Plaintiffs
GARY MARTINOVSKY, M.D., and INTEGRATED
PAIN CARE, INC.

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ATTORNEY ATTESTATION

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I hereby attest that I have on file all holograph signatures for any signatures indicated by a

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conformed signature (“/s/”) within this E-filed document or have been authorized by counsel to show

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their signatures on this Stipulation as /s/.

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Dated: April 12, 2016

By:

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/s/ Talia Saypoff
Talia B. Saypoff

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ORDER

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GOOD CAUSE APPEARING THEREFORE, and the parties’ having stipulated to the same, the
Case Management Conference
parties’ stipulation is hereby APPROVED. The Settlement Conference currently set for April 22, 2016 is
^
July 1, 2016,
continued to a date on or after May 20, 2016 at 10:30 a.m.
^
IT IS SO ORDERED.

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Dated: April 13, 2016
MAXINE M. CHESNEY
United States District Judge
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STIPULATED REQUEST FOR ORDER CHANGING TIME OF CASE MANAGEMENT CONFERENCE
Case No.: 3:16-cv-00403-MMC