Hardin v. Mendocino Coast District Hospital et al

Filing 27

STIPULATION AND ORDER re 26 STIPULATION WITH PROPOSED ORDER to Extend Time to Respond to Complaint filed by Steve Lund, Wade Sturgeon, Bob Edwards, Mendocino Coast District Hospital. Case Management Statement due 3/26/2018 by 5:00 PM. Initial Case Management Conference set for 4/4/2018 at 2:00 PM in San Francisco, Courtroom 9, 19th Floor. Signed by Judge Jon S. Tigar on January 29, 2018. (wsn, COURT STAFF) (Filed on 1/29/2018)

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FLETCHER C. ALFORD (SBN: 152314)
[e-mail]
RYAN B. POLK (SBN: 230769)
[e-mail]
GORDON REES SCULLY MANSUKHANI, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
MENDOCINO COAST DISTRICT HOSPITAL,
BOB EDWARDS, STEVE LUND AND WADE STURGEON

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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Gordon Rees Scully Mansukhani, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

(SAN FRANCISCO DIVISION)
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ELLEN HARDIN,

)
)
Plaintiff,
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vs.
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MENDOCINO COAST DISTRICT HOSPITAL, a )
government entity or agency, exact form unknown;
BOB EDWARDS, an individual; STEVE LUND, an )
individual; WADE STURGEON, an individual; and )
)
DOES 1 through 50, Inclusive,
)
)
Defendants.

CASE NO. 17-cv-05554-JST
STIPULATION TO EXTEND
TIME TO RESPOND TO
COMPLAINT;
[PROPOSED] ORDER
Complaint Filed: 09/25/17

Pursuant to Civ. L.R. 6-1(b) and 6-2, Defendants Mendocino Coast District Hospital, Bob

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Edwards, Steve Lund and Wade Sturgeon (“Defendants”) and Plaintiff Ellen Hardin

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(“Plaintiff”), by and through their respective counsel of record, hereby stipulate as follows:

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WHEREAS, Defendants agree that its counsel Gordon Rees Scully Mansukhani LLP will

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accept service via email of the Summons and Complaint for all Defendants. The Summons and

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Complaint shall be emailed by Monday January 29, 2018.

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WHEREAS, all Defendants currently have until on or about January 26, 2018 to answer
or respond to Plaintiff’s Complaint;
WHEREAS, Defendants have requested, and Plaintiff has consented to an extension of
-1STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT;
[PROPOSED] ORDER

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time for Defendants to answer or respond to Plaintiff’s Complaint to February 26, 2018;
WHEREAS, there have been no previous time modifications requested by the parties in
this action;
WHEREAS, the extension of time for Defendants to answer or respond to Plaintiff’s

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Complaint will necessitate the rescheduling of the Initial Case Management Conference, which

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is currently set for March 7, 2018 (with the Case Management Statement presently due on

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February 26, 2018 – the same day as the proposed deadline to answer or respond to the

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Complaint);
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties,

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Gordon Rees Scully Mansukhani, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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through their respective counsel, that Defendants shall answer or otherwise respond to Plaintiff’s

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Complaint by February 26, 2018.

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Dated: January 26, 2018

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GORDON REES SCULLY MANSUKHANI,
LLP

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By:

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Dated: January 26, 2018

/s/ Ryan B. Polk
Fletcher C. Alford
Ryan B. Polk
Attorneys for Defendants
MENDOCINO COAST DISTRICT
HOSPITAL, BOB EDWARDS, STEVE
LUND AND WADE STURGEON

LAW OFFICE OF TWILA S. WHITE

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By:

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/s/ Twila S. White
Twila S White
Attorney for Plaintiff
ELLEN HARDIN

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-2STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT;
[PROPOSED] ORDER

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[PROPOSED] ORDER

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PURSUANT TO THE FOREGOING STIPULATION OF THE PARTIES, IT IS

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ORDERED THAT Defendants shall answer or otherwise respond to Plaintiff’s Complaint by

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February 26, 2018. The case management conference is rescheduled for ___________________.
04/04/2018

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03/26/2018
The parties’ joint case management statement shall be due on ___________________.

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January 29
Dated: _________________, 2018
HONORABLE JON S. TIGAR
United States District Court Judge

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Gordon Rees Scully Mansukhani, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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-3STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT;
[PROPOSED] ORDER