Moss v. SAN FRANCISCO GENERAL HOSPITAL AND TRAUMA CENTER et al

Filing 26

STIPULATION AND ORDER re 23 STIPULATION WITH PROPOSED ORDER TO EXTEND DEADLINES UNDER GENERAL ORDER 56 filed by Nicole Moss, City and County of San Francisco. Signed by Magistrate Judge Kandis A. Westmore on 7/7/16. (sisS, COURT STAFF) (Filed on 7/7/2016)

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PAUL L. REIN, Esq. (SBN 43053)
CELIA MCGUINNESS, Esq. (SBN 159420)
LAW OFFICES OF PAUL L. REIN
200 Lakeside Drive, Suite A
Oakland, CA 94612
Telephone: [phone]
Facsimile:
510/832-4787
[e-mail]
MICHAEL E. GATTO, Esq. (SBN 196474)
RAINS LUCIA STERN, PC
2300 Contra Costa Boulevard, Suite 500
Pleasant Hill, CA 94523
Phone [phone]
Fax [phone]
www.RLSlawyers.com
Attorneys for Plaintiff
NICOLE MOSS
* Defendants and their counsel listed after the caption.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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NICOLE MOSS,

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Plaintiff,

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v.

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SAN FRANCISCO GENERAL
HOSPITAL AND TRAUMA CENTER;
CITY AND COUNTY OF SAN
FRANCISCO DEPARTMENT OF
PUBLIC HEALTH; CITY AND COUNTY
OF SAN FRANCISCO; and DOES 1-20,
INCLUSIVE,

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CASE NO. 3:16-cv-00072 KAW
Civil Rights
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINES
UNDER GENERAL ORDER 56

Defendants.

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STIP TO EXTEND GO 56 DEADLINES
CASE NO. 3:16-cv-00072

C:\Users\IMBRIA~1\AppData\Local\Temp\notesF8C1A4\stip to continue go 56 deadline final.docx

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DENNIS J. HERRERA, State Bar #139669
City Attorney
CHERYL ADAMS, State Bar #164194
Chief Trial Deputy
MARK D. LIPTON, State Bar #152864
Deputy City Attorney
Fox Plaza
1390 Market Street, 6th Floor
San Francisco, California 94102-5408
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO

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STIPULATION

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Plaintiff NICOLE MOSS (“Plaintiff”) and Defendant CITY AND COUNTY OF SAN

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FRANCISCO hereby jointly stipulate and request through their attorneys of record that the deadline

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to file a Notice of Need for Mediation under General Order 56 be continued to from July 1, 2016, to

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August 19, 2016. This request for an extension of time is based on the following good cause:

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1. The parties have worked cooperatively to move through General Order 56.

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2. The parties held an initial joint site inspection of the site on June 3, 2016, but due to the

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presence of patients in the Family Health Center, the parties were unable to complete the

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site inspection at that time.

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3. The parties completed the site inspection of the Family Health Center on July 7, 2016.

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4. Plaintiff needs some time to prepare a comprehensive request for injunctive relief

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pursuant to General Order 56.
5. The parties agree that Plaintiff will make best efforts to provide Defendant with a
comprehensive injunctive relief demand by July 28, 2016.
6. Plaintiff will then allow Defendant 21 days to respond to her demand before filing a
Notice for Need of Mediation by August 18, 2016.
7. The parties therefore jointly stipulate and request that the Court continue the deadline to
file a Notice for Need of Mediation to August 19, 2016.

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STIP TO EXTEND GO 56 DEADLINES
CASE NO. 3:16-cv-00072

C:\Users\IMBRIA~1\AppData\Local\Temp\notesF8C1A4\stip to continue go 56 deadline final.docx

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Date: July 7, 2016

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LAW OFFICE OF PAUL L. REIN
RAINS LUCIA STERN, PC

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By:
/s/ Celia McGuinness
CELIA McGUINNESS, ESQ.
Attorneys for Plaintiff
NICOLE MOSS

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Date: July 7, 2016

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DENNIS J. HERRERA
City Attorney
CHERYL ADAMS
Chief Trial Deputy
MARK D. LIPTION
Deputy City Attorney

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By:
/s/ Mark D. Lipton
MARK D. LIPTON, ESQ.
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO

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STIP TO EXTEND GO 56 DEADLINES
CASE NO. 3:16-cv-00072

C:\Users\IMBRIA~1\AppData\Local\Temp\notesF8C1A4\stip to continue go 56 deadline final.docx

ORDER

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Pursuant to the stipulation of the parties, and for good cause shown, IT IS SO ORDERED.

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The deadline for Plaintiff to file a Notice for Need of Mediation under General Order 56 is hereby

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continued to August 19, 2016.

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Dated: _________, 2016
7/7
U.S. Magistrate Judge Kandis A. Westmore

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STIP TO EXTEND GO 56 DEADLINES
CASE NO. 3:16-cv-00072

C:\Users\IMBRIA~1\AppData\Local\Temp\notesF8C1A4\stip to continue go 56 deadline final.docx