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Phyllis Wehlage, On Her Behalf and On Behalf v. Empres Healthcare

December 1, 2011

PHYLLIS WEHLAGE, ON HER BEHALF AND ON BEHALF OF OTHERS SIMILARLY SITUATED,
PLAINTIFFS,
v.
EMPRES HEALTHCARE, INC.; EHC THE HONORABLE CLAUDIA WILKEN
MANAGEMENT LLC; EHC FINANCIAL SERVICES LLC; EVERGREEN CALIFORNIA HEALTHCARE
LLC; EVERGREEN AT ARVIN LLC; EVERGREEN AT BAKERSFIELD LLC; EVERGREEN AT LAKEPORT
LLC; EVERGREEN AT HEARTWOOD LLC; EVERGREEN AT SPRINGS ROAD LLC; EVERGREEN AT TRACY LLC; EVERGREEN AT OROVILLE LLC; EVERGREEN AT PETALUMA LLC; EVERGREEN AT
GRIDLEY (SNF) LLC; AND DOES 1 THROUGH 100,
DEFENDANTS.



The opinion of the court was delivered by: Hon. Claudia Wilken

Robert J. Nelson (State Bar No. 132797) Lexi Hazam (State Bar No. 224457) 2 Andrew Kingsdale (State Bar No. 255669) LIEFF CABRASER HEIMANN & BERNSTEIN, LLP 3 275 Battery Street, 29th Floor San Francisco, CA 94111-3339 4 Telephone: 415.956.1000 Facsimile: 415.956.1008 5 Michael D. Thamer (State Bar No. 101440) Kathryn A. Stebner (State Bar No. 121088) 6 LAW OFFICES OF MICHAEL D. THAMER Sarah Colby (State Bar No. 194475) Old Callahan School House STEBNER & ASSOCIATES 7 12444 South Highway 3 870 Market Street, Suite 1212 Post Office Box 1568 San Francisco, CA 94102-2907 8 Callahan, CA 96014-1568 Telephone: (415) 362-9800 Telephone: (530) 467-5307 Facsimile: (415) 362-9801 9 Facsimile: (530) 467-5437 10 [Additional Counsel Appear on Signature Page] 11 Attorneys for Plaintiffs 12

STIPULATION AND [PROPOSED] ORDER RE REPLY TO OPPOSITION TO MOTION FOR LEAVE TO AMEND COMPLAINT AND MOTION TO DISMISS

3 leave to amend the complaint and motion to dismiss; 4

7 amended complaint; 8

9 conference; 10

11 response to Defendants' opposition to motion for leave to amend, as well as Defendants' motion 12 to dismiss, shall be December 6, 2011. 13 14

WROTEN & ASSOCIATES, INC.

Pursuant to Civil Local Rules 6-2 and 7-12, the parties submit the following stipulation:

Whereas on November 21, 2011 Defendants filed an opposition to Plaintiffs' motion for

Whereas the Court held that Plaintiffs must file a response within seven days (Doc. #79);

Whereas November 24, 2011 is the Thanksgiving holiday;

Whereas no other scheduling modifications have been requested pertaining to Plaintiffs'

Whereas the Court has not yet set a hearing date for the motions ...


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