Hanson v. John Muir Health

Filing 17

ORDER GRANTING REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE re 14 Letter filed by Christina Hanson. Joint Case Management Statement due by 12/11/2014. Initial Case Management Conference set for 12/18/2014 02:00 PM. Signed by Judge Phyllis J. Hamilton on 10/10/14. (nahS, COURT STAFF) (Filed on 10/10/2014)

Jody LeWitter # 124794
Jean Krasilnikoff #280450
SIEGEL LEWITTER MALKANI
1939 Harrison Street, Suite 307
Oakland, California 946 12
5 10-452-5000
5 10-452-5004 (fax)
jlewitter@,sl-employmentlaw.com
j [e-mail]
Attorneys for Plaintiff CHRISTINA HANSON

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

CHRISTINA HANSON,
Plaintiff,
v.
JOHN MUIR HEALTH, and
DOES I through X, inclusive
Defendant.

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) Case No. 4: 14-cv-3492-PJH
)

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) PLAINTIFF'S REQUEST AND [PROPOSED]
) ORDER TO RESET CASE MANAGEMENT
) CONFERENCE AND RELATED CASE
) DEADLINES
)
)

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NOW COMES the plaintiff, by and through her counsel, to request as follows:

Siege1
Le Witter
Mauiani

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WHEREAS, plaintiff filed her original complaint on August 1,2014 which was not served
on defendant, but instead plaintiff filed a First Amended Complaint on September 22,2014;
WHEREAS, plaintiff served defendant with the First Amended Complaint, Summons and
other required papers by personally delivering them to Jennifer LaValley who was the person
apparently in charge at defendant's office on September 25,2014, and copies of those same

25 papers were mailed to defendant on September 26,2014;
'939Hnrrison Street
irrite 307
?nklnnd, CA 94612
20-452-5000
il0-452-5004 (fax)

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PLAINTIFF'S REQUEST AND [PROPOSED] ORDER RESETTING CASE MANAGEMENT
CONFERENCE AND RELATED CASE DEADLINES - CASE NO. 14-3492-PJH

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WHEREAS, the case schedule currently includes the following deadlines:
October 9,2014:

Last day to
Meet and confer re: initial disclosures, early settlement,
ADR process selection, and discovery plan
File ADR certification signed by Parties and Counsel
File either Stipulation to ADR Process or Notice of Need for
ADR Phone Conference

October 23,2014:

Last day to file Rule 26(f) Report, complete initial disclosures or
state objection in Rule 26(f) Report and file Case Management
Statement per attached Standing Order re Contends of Joint Case
Management Statement
Last day to file a joint case management statement

October 30,2014:

Case Management Conference scheduled for 2:00 p.m.;

WHEREAS, defendant has not yet appeared in this action and defendant's answer is not
due until shortly before the date currently set for the Case Management Conference;

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WHEREAS, plaintiffs counsel attempted to contact defendant to meet and confer
regarding continuing the case management conference and related dates but has not yet heard
back from defendant;
WHEREAS, pursuant to the Court's order, lead counsel must appear at the Case

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Management Conference on October 30,2014 and plaintiffs lead counsel, Jody LeWitter, is
scheduled to conduct a deposition in New York on that date in case Smith v. Jefferies Group LLC,

et al., Northern District of California, Case No. 3 :13-cv-03182-TEH.

and all related dates for at least 45 days and plaintiff offers the following proposed schedule as a
suggestion to the Court:
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'939Harrison Street
itrite 307
7akland, CA 94612
i10-452-5000
il0-452-5004 (fax)

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November 26,2014: Last day to
Meet and confer re: initial disclosures, early settlement, ADR
process selection, and discovery plan
File ADR certification signed by Parties and Counsel
File either Stipulation to ADR Process or Notice of Need for
ADR Phone Conference
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PLAINTIFF'S REQUEST AND [PROPOSED] ORDER RESETTING CASE MANAGEMENT
CONFERENCE AND RELATED CASE DEADLINES - CASE NO. 14-3492-PJH

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THEREFORE, plaintiff requests that the Court continue the Case Management Conferenc

December 11,2014: Last day to file Rule 26(f) Report, complete initial
disclosures or state objection in Rule 26(f) Report and file
Case Management Statement per attached Standing Order re
Contends of Joint Case Management Statement
Last day to file a joint case management statement
December 18,2014: Case Management Conference scheduled for 2:00 p.m.

SIEGEL LEWITTER MALKANI

DATED: October 8,2014

By:

Is/ Jean Krasilnikoff
Jody I. LeWitter
Jean Krasilnikoff

Attorneys for Plaintiff

[PROPOSED] ORDER
This matter having come before the Court upon the written request of plaintiff, which is
attached hereto, it is hereby ordered that the Initial Case Management Conference and related
deadlines will be modified as follows:
November 26,2014: Last day to
Meet and confer re: initial disclosures, early settlement, ADR
process selection, and discovery plan
File ADR certification signed by Parties and Counsel
File either Stipulation to ADR Process or Notice of Need for
ADR Phone Conference

Siege1
Le Witter
Malkani

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'939
Harrison Street

December 11,2014: Last day to
File Rule 26(Q Report, complete initial disclosures or state
objection in Rule 26(Q Report and file Case Management
Statement per attached Standing Order re Contends of Joint
Case Management Statement
Last day to file a joint case management statement

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PLAINTIFF'S REQUEST AND [PROPOSED] ORDER RESETTING CASE MANAGEMENT
CONFERENCE AND RELATED CASE DEADLINES - CASE NO. 14-3492-PJH

UNIT
ED

S DISTRICT
TE
C
TA

O ORD

RT
U
O

ERED

IT Phyllis J. Hamilton
Honorable IS S
District JudgehylofJ. the on
ilt U.S.
lis Ham
Judge P
Northern District Court of California

Siege1
Le Witter
Malkani

A

H

ER

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RT

FO

NO

R NIA

DATED October 10, 2014

S

IT IS SO ORDERED.

N

F
D IS T IC T O
R

C

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'939Harrison Street
izrite 307
7aHand, CA 94612
i10-452-5000
i10-452-5004 (fax)

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ORDER RESETTING CASE MANAGEMENT
CONFERENCE AND RELATED CASE DEADLINES - CASE NO. 14-3492-PJH

PROOF OF SERVICE
I declare that I am employed in the county of Alameda, California. I am over the age of
:ighteen years and not a party to the within action. My business address is 1939 Harrison
Street, Suite 307, Oakland, California 94612.
3n October 8,2014, I served the within documents:
PLAINTIFF'S REQUEST AND [PROPOSED] ORDER TO RESET CASE MANAGEMENT
CONFERENCE AND RELATED CASE DEADLINES

In the interested party(ies) herein by sending true copies as follows:

Agent for service ofprocess

Calvin Knight
John Muir Health
1400 Treat Boulevard
Walnut Creek, CA 94597

X (BY MAIL) Each such envelope, with postage thereon fully prepaid, was placed in the

United States mail at Oakland, California. I am readily familiar with this firm's business
practice for collection and processing of correspondence for mailing with the U.S. Postal
Service pursuant to which practice the correspondence will be deposited with the U.S.
Postal Service this same day in the ordinary course of business.
(BY HAND DELIVERY) I served the above-described documents on the interested
parties listed above by personally hand delivering copies thereof to the address shown
above.
(BY MESSENGERICOURIER SERVICE) I served the above-described documents on
the interested parties listed above by arranging for hand delivery of copies thereof by with
an outside messenger service, an employee of which company picked up the documents
from the offices of Siege1 LeWitter Malkani and was directed to hand deliver copies thereof
to the address shown above.

I declare under penalty of perjury that the foregoing is true and correct and that this
ieclaration was executed on October 8,2014 at Oakland, California.

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PLAINTIFF'S REQUEST AND [PROPOSED] ORDER RESETTING CASE MANAGEMENT
CONFERENCE AND RELATED CASE DEADLINES - CASE NO. 14-3492-PJH