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 GOULD MEDICAL GROUP TO RESPOND TO COMPLAINT
PARTIES through their respective counsel, stipulate as follows:
1. Plaintiff filed a First Amended Complaint on March 16, 2012.
2. On April 2, 2012, the Court approved the Parties' Stipulation to further amendments of the First Amended Complaint and ordered that responsive pleadings be due no later than April 17, 2012.
3. On April 16, 2012, Defendants Sutter Health and Sutter Gould Medical Foundation ("Sutter Defendants") filed a Motion to Dismiss.
4. Requiring Gould Medical Group to file responsive pleadings now and again after Sutter Defendants' Motion to Dismiss is ruled on will create unnecessary expense to both parties and waste valuable court resources.
5. Parties stipulate to further extend time for the Group to respond to Plaintiff's Complaint until after a ruling on the Sutter Defendants' Motion to Dismiss and/or any further amended Complaint, if any, is filed by Plaintiff in response to the Motion to Dismiss.
IT HEREBY ORDERED that the time for Gould Medical Group to respond to Plaintiff's Complaint is extended until ten days after a ruling on the Sutter Defendants' Motion to Dismiss or ten days after any further amended Complaint, if any, is filed by Plaintiff in response to the Motion to Dismiss, whichever date is later.
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