Martinez et al v. Corizon Health Inc. et al

Filing 25

ORDER GRANTING 24 STIPULATION TO EXTEND DEADLINE TO AMEND PLEADINGS. Amended Pleadings due by 9/30/2016. Signed by Judge Jeffrey S. White on 7/28/16. (jjoS, COURT STAFF) (Filed on 7/28/2016)

Case 4:16-cv-00881-JSW Document 24 Filed 07/25/16 Page 1 of 3

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JOHN L. BURRIS ESQ., SBN 69888
BENJAMIN NISENBAUM, ESQ., SBN 222173
JAMES COOK, ESQ., SBN 300212
LAW OFFICES OF JOHN L. BURRIS
Airport Corporate Centre
7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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TANTI MARTINEZ, individually; Minor M.M.,
by and through his Guardian Ad Litem Corrina
Mendoza; Minor T.M., by and through her
Guardian Ad Litem Corrina Mendoza; Minor
I.M., by and through his mother and Guardian
Ad Litem, Vanessa Hernandez,

CASE NO.: 3:16-cv-00881 JSW

STIPULATION TO EXTEND DEADLINE
TO AMEND PLEADINGS AND ORDER

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Plaintiffs,

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vs.

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CORIZON HEALTH, INC., a Delaware
Corporation; HAROLD ORR, M.D.; TEHMINA
KANWAL, M.D.; COUNTY OF ALAMEDA, a
municipal corporation; SHERIFF GREGORY J.
AHERN, in his individual and official capacities;
and DOES 1-50, inclusive,
Defendants.

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STIPULATION

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1.

WHEREAS, the deadline to Amend Pleadings in this action is currently set for

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September 16, 2016 (as reflected in Docket Entry No. 20, pertaining to Case Management

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Conference held on June 3, 2016).

STIPULATION TO EXTEND DEADLINE TO AMEND PLEADINGS AND ORDER

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Case 4:16-cv-00881-JSW Document 24 Filed 07/25/16 Page 2 of 3

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2.

WHEREAS, the parties have diligently pursued discovery. Specifically, Plaintiffs

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propounded written discovery on Defendants CORIZON HEALTH, INC. and COUNTY OF

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ALAMEDA on June 24, 2016, making their responses due July 25, 2016.

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3.

WHEREAS, Defendants have requested a two-week extension to respond to the

written discovery propounded on them, making their responses due by August 8, 2016.

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4.

WHEREAS, Plaintiffs’ counsel is currently scheduled for a two week trial starting on

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August 22, 2016 before Judge Breyer in Sheehan v. City and County of San Francisco, et al. Case
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No. C 09-03889 CRB.
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5.

WHEREAS, Plaintiffs anticipate the discovery responses from Defendants COUNTY

and CORIZON HEALTH, INC. to be voluminous and require substantial time to review.
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WHEREAS, thorough review of said discovery responses is necessary to determine

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the identities and roles of unnamed Defendant DOES, in order to prepare an Amended Pleading that

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properly identifies all unnamed Defendant DOES.

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7.

WHEREFORE, the parties stipulate and respectfully request a two-week extension of

the deadline to Amend Pleadings, from September 16, 2016, to September 30, 2016.

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IT IS SO STIPULATED.
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LAW OFFICES OF JOHN L. BURRIS

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Dated: July 25, 2016

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__/s/ Ben Nisenbaum___
Ben Nisenbaum,
Attorney for Plaintiffs

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THE LAW OFFICES OF NANCY E. HUDGINS

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Dated: July 25, 2016

__/s/ Matthew M. Grigg___
Matthew M. Grigg
Attorney for Defendants

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STIPULATION TO EXTEND DEADLINE TO AMEND PLEADINGS AND ORDER

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Case 4:16-cv-00881-JSW Document 24 Filed 07/25/16 Page 3 of 3

ORDER

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GOOD CAUSE SHOWN, the Court hereby grants the parties’ Stipulation to extend the

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Deadline to Amend Pleadings by two weeks. Pursuant to this Order, the Last Day to Amend

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Pleadings is September 30, 2016.

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IT IS SO ORDERED.

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July 28, 2016
Dated:_______________

__________________________
Hon. Jeffrey S. White
UNITED STATES DISTRICT COURT

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STIPULATION TO EXTEND DEADLINE TO AMEND PLEADINGS AND ORDER

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