UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
February 16, 2012
BETH A. RHODES, M.D.,
GOULD MEDICAL SUTTER HEALTH, A CALIFORNIA CORPORATION,
SUTTER GOULD MEDICAL FOUNDATION, A CALIFORNIA CORPORATION,
THE GOULD MEDICAL GROUP, INC., A CALIFORNIA CORPORATION, DEFENDANTS.
DILLINGHAM & MURPHY, LLP CARLA J. HARTLEY (SBN 117213) DANIELLE L. TIZOL (SBN 259702) 225 BUSH STREET, 6TH FLOOR SAN FRANCISCO, CALIFORNIA 94104-4207 TELEPHONE: (415) 397-2700 FACSIMILE: (415) 397-3300 Attorneys for Defendant GOULD MEDICAL GROUP, INC.
STIPULATION AND [PROPOSED] ORDER TO FURTHER EXTEND TIME FOR DEFENDANT GROUP TO RESPOND TO COMPLAINT
PARTIES through their respective counsel, stipulate as follows:
1. Parties previously stipulated to extend time for Defendant GOULD MEDICAL GROUP, INC. (the "Group") to respond to Plaintiff's, BETH A. RHODES, M.D. ("Plaintiff"), Complaint until February 24, 2012.
2. On February 10, 2012, Plaintiff filed an Opposition to Defendants Sutter Health and Sutter Gould Medical Foundation's Motion to Dismiss for Failure to State a Claim and for a More Definite Statement. In that Opposition, Plaintiff indicated her intent to file an Amended Complaint.
3. In light of Plaintiff's intention to file an Amended Complaint, Parties agree that requiring the Group to respond before the Amended Complaint is filed will cause unnecessary expense to both parties and waste valuable court resources.
4. Parties stipulate to further extend time for the Group to respond to Plaintiff's Complaint until such time as the Court orders all Defendants to respond to Plaintiff's anticipated Amended Complaint.
IT IS SO ORDERED.
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