Doe v. Washington Township Healthcare District et al

Filing 38

STIPULATION AND ORDER re 37 Stipulation and [Proposed] Order to Extend Discovery (First Request) filed by Jane Doe. Signed by Magistrate Judge Howard R. Lloyd on 10/28/2013. (hrllc1, COURT STAFF) (Filed on 10/28/2013)

*E-Filed: October 28, 2013*

I . Jason 0. Runckel, Esq. (California SBN: 198361)
Thomas M. O'Connor, Esq. (California SBN: 172236)
2 William D. O'Malley, Esq. (California SBN: 129605)
3 O'CONNOR, RUNCKEL & O'MALLEY LLP
1277 Treat Boulevard, Suite 810
Walnut Creek, CA 94597
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Telephone: [phone]
5 Facsimile: [phone]

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Attorneys for Plaintiff, Jane Doe

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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Case No. CV 13-00745 HRL

JANE DOE,

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WASHINGTON TOWNSHIP HEALTH CARE
DISTRICT, WASHINGTON HOSPITAL, JON
QUIANZON and ROES I to 25, inclusive,

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Defendants.

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND DISCOVERY
(FIRST REQUEST)

Plaintiff,

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STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY
(FIRST REQUEST)

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STIPULATION

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Pursuant to LR 6.1(b) and 6.2, the parties, by and through their respective attorneys of
record, stipulate and agree that the existing discovery deadlines be extended 30 days in accordance

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with the information set forth below.

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I.

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The parties have completed the following discovery:

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Discovery Completed

The parties have made initial disclosures pursuant to Fed. R. Civ. Proc. 26

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STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY (FIRST REQUEST)
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The parties have served and responded to written discovery.

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The parties have subpoenaed various custodians of records and have received responses

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to those subpoenas.

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The following depositions have been taken:

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Jane Doe (Plaintiff)

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Michael Platzbecker

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Joanne Furlong

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Hai Dang

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Thao Moscheiti

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II.

Remaining Discovery
The following depositions remain:

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Bryant Welch, currently scheduled for October 15, 2013

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Kadeer Halimi, M.D., currently scheduled for October 18, 2013

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Gurpreet Singh, currently scheduled for October 28, 2013

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Fremont Police Officer, Ricardo Cortes, currently scheduled for October 30, 2013

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Fremont Police Officer (Ret.) Teresa Martinez, cutTently scheduled for October 30,

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2013

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Bill Wescott, currently scheduled for November 7, 2013

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Joey Schreifer, currently scheduled for November 7, 2013

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Christopher Sato-Pe11y, M.D., currently scheduled for October 31,2013
Kaveri Patel, M.D., currently scheduled for October 31,2013

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Supplemental written discovery as needed following the last depositions in November

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The parties may need to issue additional subpoenas

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STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY (FIRST REQUEST)
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Any additional discovery the parties deem necessary within the scope of permissible

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discovery under the Federal Rules of Civil Procedure.

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III.

Reasons Discovery Cannot Be Completed

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The depositions of Bryant Welch, Bill Wescott and Joey Schreifer were originally
scheduled in early September and were continued until October 15,2013 and November 7, 2013.

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An additional delay was incurred when Ms. Schreifer became unavailable due to a family medical

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emergency. Defendant's counsel has two trial scheduled in November and therefore he was

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unavailable for the majority of October due to expert witness depositions for said trials. The

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parties therefore have had to go into November to complete depositions.
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depositions and current discovery deadline does'not allow enough time within which to complete

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it. Accordingly the parties stipulate and agree to continue the non-expert discovery deadline 30

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days to allow enough time to conduce any potential supplemental discovery.

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IV.

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Proposed Discovery Schedule

The parties stipulate and agree to the following 30 day extension of the existing Fact
Discovery Cutoff:
Current Date

Proposed Date

Fact Discovery Cutoff

December 2, 20 13

January 2, 2014

Designation of Experts with Reports

February 3, 2014

February 3, 2014

Designation of Rebuttal Experts with
Reports

March 4, 2014

March 4, 2014

Expert Discovery Cutoff

April 4, 2014

April4, 2014

Final Pretrial Conference

June 19,2014 at 1:30pm

June 19,2014 at 1:30pm

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Additional discovery may be required following the completion of the scheduled

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STIPULATION AND !PROPOSED] ORDER TO EXTEND DISCOVERY (FIRST REQUEST)
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TBD

Jury Trial
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Dated: October .1]_, 20 13

O'CONNOR, RUNCKEL & O'MALLEY

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J son 0. Runckel
ttorney for Plaintiff, Jane Doe

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GALLOWAY, LUCCHESE, EVERSON &
PICCHI

Dated: October /&,2013

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Martin J. Everson
Attorney for Defendant Washington Township
Healthcare District

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Pursuant to Stipulation it is so ORDERED that the Fact Discovery Cutoff is hereby

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ORDER

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extended to January 2, 2014. All other scheduled dates remain in place.

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10/28/13
Dated: ~~~~~~-

Howard R. Lloyd
United States Magistrate Judge

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STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY (FIRST REQUEST)
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