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Sandra Matsumura, Individually and On Behalf of All Others Similarly Situated v. Fremont-Rideout Health Group
April 6, 2011
SANDRA MATSUMURA, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
FREMONT-RIDEOUT HEALTH GROUP, ETC., ET AL., DEFENDANT.
The opinion of the court was delivered by: Judge: Morrison C. England, Jr.
SEYFARTH SHAW LLP Alfred L. Sanderson, Jr. (SBN 186071) Email: firstname.lastname@example.org Brandon R. McKelvey (SBN 217002) Email: email@example.com Anthony J. Musante (State Bar No.(SBN 252097) Email: firstname.lastname@example.org 400 Capitol Mall, Suite 2350 Sacramento, California 95814-4428 Telephone: (916) 448-0159 Facsimile: (916) 558-4839 Attorneys for Defendant RIDEOUT MEMORIAL HOSPITAL erroneously sued as FREMONT-RIDEOUT HEALTH GROUP, a non-profit corporation HARRIS & RUBLE Alan Harris (SBN 146079) Matthew Kavanaugh (SBN 239961) 6424 Santa Monica Blvd. Los Angeles, CA 90038 Telephone: (323) 962-3777 Facsimile: (323) 962-3004 Email: email@example.com Attorneys for Plaintiff SANDRA MATSUMURA
STIPULATION AND ORDER TO MODIFY
THE PRETRIAL SCHEDULING ORDER
TO CONTINUE THE SETTLEMENT
Complaint Filed: July 2, 2009
Pursuant to Rule 16(b) of the Federal Rules of Civil Procedure, Local
Rules 240 and 270,
and the Court's Pretrial Scheduling Order, Plaintiff Sandra
Matsumura and Defendant Rideout
Memorial Hospital ("Defendant") hereby submit this Stipulation to
Modify the Pretrial 2
Scheduling Order to continue the settlement conference. 3
On October 19, 2010, this Court issued a Pretrial Scheduling Order in this matter.
Pursuant to the Order, a Settlement Conference was set before Judge Frank C. Damrell, Jr. on April 15, 2011, at 2:00 p.m. Since the Scheduling Order was issued, the parties have attempted 6 to schedule plaintiff's deposition, but have been unable to do so, primarily as a result of 7 plaintiff's work schedule. Defendant asserts that because plaintiff has yet to be deposed, a Settlement Conference at this time would likely be unproductive. Accordingly, the parties seek a 9 modification of the Pretrial Scheduling Order to continue the Settlement Conference. 10
Defendant has been diligent in attempting to schedule plaintiff's
first noticed plaintiff's deposition for December 21, 2010.
Plaintiff was unable to attend on that 12 date due to a conflict with
her work schedule so counsel for the parties discussed alternative 13
dates. Through January and February, several dates were proposed, but
Plaintiff, or counsel for 14 the parties, had scheduling conflicts.
Defendant then noticed plaintiff's deposition for March 31, 15
2011. Plaintiff was unavailable for the noticed date due to her work
schedule. Thereafter, 16 counsel for both parties conferred and
determined that May 5, 2011 was the soonest the 17 deposition could
occur, and the deposition was set for that date. Defendant asserts
that a 18
Settlement Conference occurring prior to plaintiff's deposition would
be premature and have 19 little chance of resolving the case.
Accordingly, good cause exists to modify the Pretrial 20
Scheduling Order to continue the Settlement Conference until after plaintiff has been deposed. 21
The parties have conferred and agreed upon a date for the Settlement
plaintiff's deposition: June 17, 2011. In addition, defendant has
confirmed that Judge Damrell is 23 available to conduct the Settlement
Conference on June 17, 2011 at 1:30 p.m. The new date for 24 the
Settlement Conference will have no impact on the remaining dates in
the Pretrial Scheduling 25
IT IS STIPULATED AS FOLLOWS:
The Pretrial Scheduling Order shall be modified to continue the
from April 15, 2011 to June 17, 2011 at 1:30 p.m. before Judge
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