Simonmed Imaging Inc. v. Dignity Healthcare Inc.

Filing 37

STIPULATION AND ORDER re 36 STIPULATION WITH PROPOSED ORDER Re Postponing Certain Schedule Dates Pending Settlement Agreement filed by Dignity Health Motion Hearing set for 4/5/2018 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco before Judge Jon S. Tigar. Signed by Judge Jon S. Tigar on January 17, 2018. (wsn, COURT STAFF) (Filed on 1/17/2018)

Download PDF
1 2 3 4 5 6 7 Brian Selden (State Bar No. 261828) bgselden@jonesday.com Rowan Mason (State Bar No. 259586) rmason@jonesday.com JONES DAY 555 California Street, 26th Floor San Francisco, California 94104 Telephone: 415-626-3939 Facsimile: 415-875-5700 Attorneys for Defendant Dignity Health 8 9 10 11 12 13 14 15 David J. Millstein (State Bar No. 87878) dmillstein@millstein-law.com Gerald S. Richelson (State Bar No. 267705) grichelson@millstein-law.com MILLSTEIN & ASSOCIATES 100 The Embarcadero, Suite 200 San Francisco, CA 94105 Telephone: (415) 348-0348 Facsimile: (415) 348-0336 Attorneys for Plaintiff: SimonMed Imaging, Inc. 16 17 18 UNITED STATES DISTRICT COURT 19 NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION 20 21 SIMONMED IMAGING, INC., an ARIZONA CORPORATION, 22 23 24 25 26 Plaintiff, v. DIGNITY HEALTH, a DOMESTIC NONPROFIT CALIFORNIA CORPORATION, Does 1 through 10, CASE NO.: 17-cv-02907-JST JOINT STIPULATION AND PROPOSED ORDER RE POSTPONING CERTAIN SCHEDULE DATES PENDING SETTLEMENT AGREEMENT Defendant. 27 28 JOINT STIPULATION AND PROPOSED ORDER POSTPONING SCHEDULE DATES Case No.: 17-cv-02907-JST 1 2 3 4 Plaintiff SimonMed Imaging, Inc. (“SimonMed”) and Defendant Dignity Health (“Dignity”) (collectively “the Parties”) hereby jointly request and stipulate as follows: WHEREAS the Parties filed a Joint Stipulation and Proposed Order re Schedule on December 7, 2017 setting out dates for motions on the pleadings; 5 WHEREAS the Court signed the Proposed Order re Schedule on December 11, 2017; 6 WHEREAS the Court postponed the next Further Case Management Conference until 7 8 9 10 11 March 1, 2018 at 2pm; WHEREAS the Parties have now reached an agreement in principle on framework for settlement, including price for transfer of ownership, and are currently attempting to draft final settlement terms; WHEREAS the Parties seek to avoid any unnecessary litigation costs including the filing 12 of motions and new pleadings by postponing all impending deadlines by approximately five 13 weeks while the Parties finalize a settlement agreement. 14 15 Based on the foregoing, the Parties hereby stipulate to the following modified briefing schedule and proposed hearing date for the Motion(s): 16 17 Event Date Deadline to either file Motion(s) or, in the alternative, file a responsive pleading February 22, 2018 Deadline to file oppositions to Motion(s) March 8, 2018 Deadline to file replies to Motions(s) March 15, 2018 23 Hearing on Motions April 5, 2018 at 2 p.m. Courtroom 9, 19th Floor 24 Deadline to file any further amended pleadings (if Motion(s) granted in whole or part) Within 14 days of notice of the Court’s order on the Motion(s) Deadline to respond to further amended pleadings Within 14 days of the filing of further amended pleadings, unless amended pleadings are not required, in which case response(s) are due within 14 days of the Court’s order on the Motion(s) 18 19 20 21 22 25 26 27 28 -1- JOINT STIPULATION AND PROPOSED ORDER POSTPONING SCHEDULE DATES Case No.: 17-cv-02907-JST 1 2 3 Dated: January 16, 2018 MILLSTEIN & ASSOCIATES 4 By: /s/ Gerald Richelson David Millstein Gerald Richelson 5 6 Attorneys for Plaintiff SIMONMED IMAGING, INC. 7 8 9 10 11 12 13 14 JONES DAY Dated: January 16, 2018 By: /s/ Rowan Mason Brian Selden Rowan Mason Attorneys for Defendant DIGNITY HEALTH 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- JOINT STIPULATION AND PROPOSED ORDER POSTPONING SCHEDULE DATES Case No.: 17-cv-02907-JST 1 2 3 4 FILER’S ATTESTATION I attest under penalty of perjury that concurrence in the filing of this document has been obtained from all signatories. Dated: January 16, 2018 JONES DAY 5 By: /s/ Rowan Mason Brian Selden Rowan Mason 6 7 Attorneys for DIGNITY HEALTH 8 9 10 11 [PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. 12 13 January 17 DATED: __________________, 2018 14 15 16 HONORABLE JON S. TIGAR UNITED STATES DISTRICT JUDGE 17 18 19 20 21 22 23 24 25 26 27 28 -3- JOINT STIPULATION AND PROPOSED ORDER POSTPONING SCHEDULE DATES Case No.: 17-cv-02907-JST

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?