Lapachet v. California Forensic Medical Group, Inc. et al

Filing 29

ORDER by Judge Haywood S. Gilliam, Jr. Granting 28 Stipulation Briefing Schedule for Defendants' Motions to Change Venue. (ndrS, COURT STAFF) (Filed on 2/23/2017)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MICHAEL J. HADDAD (SBN 189114) JULIA SHERWIN (SBN 189268) T. KENNEDY HELM (SBN 282319) MAYA SORENSEN (SBN 250722) HADDAD & SHERWIN LLP 505 Seventeenth Street Oakland, CA 94612 Telephone: (510) 452-5500 Facsimile: (510) 452-5510 SANJAY S. SCHMIDT (SBN 247475) LAW OFFICE OF SANJAY S. SCHMIDT 1388 Sutter Street, Suite 810 San Francisco, CA 94109 Telephone: (415) 563-8583 Facsimile: (415) 223-9717 Attorneys for Plaintiff UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) Plaintiff, ) ) vs. ) ) CALIFORNIA FORENSIC MEDICAL GROUP, INC., TAYLOR FITHIAN, M.D., ) ) LANI ANTONIO, P.A., VERONICA ) BERGHORST, R.N., JESSAMAE ) TRINIDAD, R.N., GRASHIKA DEVENDRA, ) Psychiatric R.N., TABITHA KING, L.V.N., ) AMARDEEP TAWANA, L.V.N., JUDITH ) ALEJANDRE, L.V.N. COUNTY OF ) ) STANISLAUS, a municipal corporation, ) Stanislaus County Sheriff ADAM CHRISTIANSON, and DOES 1-50, Jointly ) ) and Severally, ) ) Defendants. ) ) ) ) ) ) ) JEREMY LAPACHET, Case No. 3:16-cv-06959-HSG STIPULATION AND ORDER RE: BRIEFING SCHEDULE FOR DEFENDANTS' MOTIONS TO CHANGE VENUE No. 3:16-CV-06959-HSG: STIP & ORDER RE: MOTION TO CHANGE VENUE 1 STIPULATION 2 3 4 The parties, by and through their respective attorneys of record, hereby stipulate and agree as follows: 5 1. 6 On February 13, 2017, County of Stanislaus filed a Motion to Change Venue, and the Court set a Motion Hearing for April 13, 2017 at 11:00 a.m. 7 2. On February 17, 2017 the CFMG Defendants filed a Motion to Dismiss or in 8 the Alternative Transfer Venue, and Court set the hearing date for April 27, 9 2017 at 2:00 p.m. 10 11 2. Stanislaus’ Motion to Change Venue to April 27, 2017 at 2:00 p.m. 12 13 On February 17, 2017, the Court reset the hearing date for County of 3. The parties jointly request that the Court continue the briefing schedule as follows: 14 a) Plaintiff's Opposition due on or before April 3, 2017; 15 b) Defendants’ Replies due on or before April 10, 2017. 16 4. Good cause exists, because Plaintiff’s co-counsel, Haddad & Sherwin LLP, 17 just appeared in this action on February 17, 2017 (Doc. 26), and Plaintiff’s counsel has several 18 other major deadlines and responsibilities in other pending cases that would make it impossible 19 20 21 to adequately brief opposition papers to Defendants’ motions by the current deadline of February 27, 2017. Further, since the hearing date for both motions already has been consolidated to April 27, 2017, there is sufficient time for the parties and court to brief and review responses and replies according to normal deadlines pegged to the new hearing date. 22 5. 23 For these reasons, all parties stipulate and request that this Court enter the following order adjusting the briefing schedule for these motions. 24 25 No. 3:16-CV-06959-HSG: STIP & ORDER RE: MOTION TO CHANGE VENUE 1 2 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. Dated: February 23, 2017 HADDAD & SHERWIN LLP 3 /s/ Michael J. Haddad 4 MICHAEL J. HADDAD Attorneys for Plaintiff JEREMY LAPACHET 5 6 7 Dated: February 22, 2017 BERTLING & CLAUSEN, LLP 8 /s/ Jemma Saunders* JEMMA PARKER SAUNDERS Attorneys for Defendants CFMG, Fithian, Antonio, Berghorst, Trinidad, Devendra, King, Tawana, Alejandre 9 10 11 12 13 14 Dated: February 22, 2017 RIVERA & ASSOCIATES /s/ Jesse Manuel Rivera* JESSE MANUEL RIVERA Attorneys for Defendants County of Stanislaus, Sheriff Adam Christianson 15 16 17 18 *Ms. Saunders and Mr. Rivera give their consent to file this stipulation with their electronic signatures. 19 20 21 22 23 24 25 No. 4:16-CV-06959-HSG: STIP & PROPOSED ORDER RE: MOTION TO CHANGE VENUE 3 ORDER 1 2 PURSUANT TO STIPULATION, AND GOOD CAUSE APPEARING, IT IS SO 3 ORDERED. Plaintiff's Responses in opposition to Defendants’ motions to change venue are 4 due no later than April 3, 2017, and Defendants' replies are due no later than April 10, 2017. 5 6 7 8 Dated: February 23, 2017 _______________________________ Hon. Haywood S. Gilliam, Jr. UNITED STATES DISTRICT COURT 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 No. 4:16-CV-06959-HSG: STIP & PROPOSED ORDER RE: MOTION TO CHANGE VENUE 4

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