UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
July 10, 2012
UNITED STATES OF AMERICA EX REL.
CHRIS MCGOWAN, AN INDIVIDUAL,
KAISER FOUNDATION HEALTH PLAN, INC., A CALIFORNIA CORPORATION, DEFENDANT.
The opinion of the court was delivered by: Hon. Jeffrey S. White United States District Judge
STIPULATION AND [PROPOSED] ORDER RE BRIEFING SCHEDULE AND CONFERENCE INITIAL CASE MANAGEMENT
WHEREAS, the initial case management conference in this matter is currently set for July 27, 2012 at 1:30 p.m.;
WHEREAS, Defendant Kaiser Foundation Health Plan, Inc. ("Kaiser") has filed a motion 27 to dismiss the First Amended Complaint and that motion is set for hearing on September 28, 2012 28 at 9:00 a.m.;
WHEREAS, Relator Chris McGowan's opposition to the motion to dismiss is currently 2 due to be filed on July 10, 2012 and Kaiser's reply brief is currently due to be filed on July 17, 3
WHEREAS, Relator needs additional time to prepare an opposition brief due to the press 5 of other business of Relator's counsel, the parties believe that the case management conference 6 should be continued to the same date as the hearing on the motion to dismiss, and the parties have 7 agreed not to conduct any discovery until after the Court rules on the motion to dismiss unless the 8 2012; and 4
Court orders otherwise or the scheduling order entered by the Court sets discovery deadlines 9 which would, actually or as a practical matter, require the parties to conduct discovery prior to the 10
IT IS HEREBY STIPULATED AND AGREED between the undersigned counsel for
1. McGowan's opposition to the motion to dismiss shall be filed on or before July 24, 14 Court's ruling on the motion to dismiss. 11 McGowan and Kaiser as follows: 13 2012.
2. Kaiser's reply in support of the opposition shall be filed on or before August 7,2012.
3. The initial case management conference, currently set for July 27, 2012 at 1:30 p.m., shall be reset to September 28, 2012 at 1:30 p.m. or as soon thereafter as the Court's calendar permits.
Dated: July 9, 2012 WILLIAM D. BEIL 2 JASON M. HANS ROUSE HENDRICKS GERMAN MAY PC JEFFREY E. FAUCETTE 4 SKAGGS FAUCETTE LLP 5 6 By: /s/ Jason M. Hans 7 Attorneys for Relator CHRIS McGOWAN 8 9 Dated: July 9, 2012 DAVID W. O'BRIEN 10 JUSTIN P. MURPHY NIMROD HAIM AVIAD CROWELL & MORING LLP By: /s/ David O'Brien Attorneys for Defendant KAISER FOUNDATION HEALTH PLAN, INC.
PURSUANT TO STIPULATION, IT IS SO ORDERED. 16
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