C. M. v. MarinHealth Medical Group, Inc.

Filing 25

ORDER granting 24 Stipulation to Reset Deadlines as to 22 MOTION to Dismiss. Responses due by 12/12/2023. Replies due by 12/28/2023. Signed by Judge William H. Orrick on 11/14/2023. (jmd, COURT STAFF) (Filed on 11/14/2023)

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Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: [phone] F: [phone] | clarksonlawfirm.com

Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: [phone] F: [phone] | clarksonlawfirm.com

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CLARKSON LAW FIRM, P.C.
Ryan J. Clarkson (SBN 257074)
[e-mail]
Yana Hart (SBN 306499)
[e-mail]
Tiara Avaness (SBN 343928)
[e-mail]
Valter Malkhasyan (SBN 348491)
[e-mail]
22525 Pacific Coast Highway
Malibu, CA 90265
Tel: [phone]
Fax: [phone]
Counsel for Plaintiff and the Proposed Classes

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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C.M., individually, and on behalf of all others
similarly situated,

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CLASS ACTION
Plaintiff,

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Case No.: 23-cv-04179-WHO

Assigned to Hon. William H. Orrick
vs.
MARINHEALTH MEDICAL GROUP, INC.
Defendant.

JOINT STIPULATION AND [PROPOSED]
ORDER TO MODIFY THE BRIEFING
SCHEDULE RE: DEFENDANT
MARINHEALTH MEDICAL GROUP,
INC.’S MOTION TO DISMISS CLAIMS 6-9
OF THE COMPLAINT
[Proposed Order filed concurrently herewith]

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Complaint Filed: August 16, 2023
Trial Date: None

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JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY THE BRIEFING SCHEDULE
RE: DEFENDANT MARINHEALTH MEDICAL GROUP, INC.’S MOTION TO DISMISS CLAIMS
6-9 OF THE COMPLAINT

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Through their undersigned counsel, Plaintiff C.M. (“Plaintiff”) and Defendant MarinHealth

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Medical Group, Inc. (“Defendant”) (collectively the “Parties”) jointly request that the Court

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modify the briefing schedule on Defendant’s Motion to Dismiss (DKT. No. 22). In support of their

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stipulated request, the counsel for the Parties declare as follows:

Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: [phone] F: [phone] | clarksonlawfirm.com

Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: [phone] F: [phone] | clarksonlawfirm.com

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1.

WHEREAS, On November 7, 2023, Defendant filed its Motion to Dismiss Plaintiff’s

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Claims 6-9 (DKT. 22), which is set for hearing on January 17, 2023, before the Honorable William

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H. Orrick;

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2.

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WHEREAS, pursuant to Local Rule 7-3(a), Plaintiff’s Opposition to Defendant’s

Motion is currently due on November 21, 2023;
3.

WHEREAS, pursuant to Local Rule 7-3(c), Defendant’s Reply Brief in support of its

Motion is currently due on November 28, 2023;
4.

WHEREAS, on November 8, 2023, Plaintiff’s counsel conferred with Defense counsel,

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requesting a three (3) week extension in time to file Plaintiff’s Opposition to the Motion to Dismiss

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due to scheduling conflicts. Defendant’s counsel agreed to Plaintiff’s extension request.

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5.

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NOW, THEREFORE, the Parties hereby jointly stipulate that the Court approve the

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The requested extension will not prejudice either party.

Parties’ proposed briefing schedule associated with Defendant’s Motion, as follows:
a. Plaintiff’s Opposition to Defendant’s Motion to Dismiss shall be filed on or
before December 12, 2023; and
b. Defendant’s Reply in Support of its Motion to Dismiss shall be filed on or
before December 28, 2023.
c. The hearing on Motion to Dismiss currently set for January 17, 2024, shall
remain unchanged.
IT IS SO STIPULATED.

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JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY THE BRIEFING SCHEDULE
RE: DEFENDANT MARINHEALTH MEDICAL GROUP, INC.’S MOTION TO DISMISS CLAIMS
6-9 OF THE COMPLAINT

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DATED: November 14, 2023

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/s/ Yana Hart
Yana Hart, Esq.
Ryan Clarkson, Esq.
Tiara Avaness, Esq.
Valter Malkhasyan, Esq.

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Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: [phone] F: [phone] | clarksonlawfirm.com

Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: [phone] F: [phone] | clarksonlawfirm.com

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CLARKSON LAW FIRM, P.C.

DATED: November 14, 2023

CONSTANGY, BROOKS, SMITH &
PROPHETE, LLP
/s/ David Yudelson
David Yudelson, Esq.
Sydney Wright, Esq.
Catlyn Wiegand, Esq.
Samuel Park, Esq.

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JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY THE BRIEFING SCHEDULE
RE: DEFENDANT MARINHEALTH MEDICAL GROUP, INC.’S MOTION TO DISMISS CLAIMS
6-9 OF THE COMPLAINT

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ATTESTATION UNDER LOCAL RULE 5-1(i)(3)

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Pursuant to Civil Local Rule 5-1(i)(3), the undersigned filer hereby attests that all signatories

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listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized

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the filing.

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DATED: November 14, 2023

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CLARKSON LAW FIRM, P.C.
/s/ Yana Hart

Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: [phone] F: [phone] | clarksonlawfirm.com

Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: [phone] F: [phone] | clarksonlawfirm.com

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JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY THE BRIEFING SCHEDULE
RE: DEFENDANT MARINHEALTH MEDICAL GROUP, INC.’S MOTION TO DISMISS CLAIMS
6-9 OF THE COMPLAINT

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The Court having reviewed and considered the Parties’ Joint Stipulation to (1) Modify

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Briefing Schedule on Defendant’s Motion to Dismiss, and good cause appearing, hereby grants the

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Joint Stipulation as follows:

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Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: [phone] F: [phone] | clarksonlawfirm.com

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Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: [phone] F: [phone] | clarksonlawfirm.com

[PROPOSED] ORDER

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a. Plaintiff’s Opposition to Defendant’s Motion to Dismiss shall be filed on or
before December 12, 2023; and
b. Defendant’s Reply in Support of its Motion to Dismiss shall be filed on or
before December 28, 2023.
c. The hearing on Motion to Dismiss currently set for January 17, 2024, shall
remain unchanged.
IT IS SO ORDERED.

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DATE: November 14, 2023

___________________________
William H. Orrick
United Stated District Judge

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JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY THE BRIEFING SCHEDULE
RE: DEFENDANT MARINHEALTH MEDICAL GROUP, INC.’S MOTION TO DISMISS CLAIMS
6-9 OF THE COMPLAINT