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Elsy Garcia De Mira, Individually, and On Behalf of All Others v. Hcr Manorcare; Hcr Manorcare

October 26, 2012

ELSY GARCIA DE MIRA, INDIVIDUALLY, AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFF,
v.
HCR MANORCARE; HCR MANORCARE MEDICAL SERVICES OF FLORIDA, LLC; MANOR CARE, INC.; AND DOES 1 THROUGH 10 INCLUSIVE DEFENDANTS.



CASE NO. 12-cv-04092 STIPULATIONTOEXTENDTIMEFOR PARTIESTOEXCHANGEINITIAL DISCLOSURESBYONEWEEK; [PROPOSED]ORDER Complaint Filed: August 03, 2012

Pursuant to Local Rule 16-2 the parties, by and through their respective counsel, stipulate and agree that Plaintiff ELSY GARCIA DE MIRA ("Plaintiff") and Defendants HCR 3 MANORCARE, INC. (erroneously sued as HCR MANORCARE); HCR MANORCARE 4 MEDICAL SERVICE OF FLORIDA, LLC and MANORCARE, INC. (collectively, 5 Defendants) shall both mutually have an extension of one week, or until October 16, 2012, to 6 produce and exchange Initial Disclosures pursuant to Federal Rules of Civil Procedure, Rule 7 26. The Order Setting Initial Case Management Conference requires that Initial Disclosures to 8 be completed by October 9, 2012, but due to the limited availability of counsel and because a 9 modest extension is in the interests of justice, the parties agree to an extension of one week, 10 until October 16, 2012, to complete the exchange.

IT IS SO STIPULATED.

Pursuant to Local Rule 5-1, I, Jennifer L. Connor, obtained concurrence from 14 signatory in filing.

SPIRO MOORE LLP 13 16 17 Date: October 3, 2012 /s/ Jennifer L. Connor IRA SPIRO 18 JENNIFER L. CONNOR 19 DENISE L. DIAZ JUSTIN MARQUEZ 20 Attorneys for Plaintiff Date: October 3, 2012 LITTLER MENDELSON, P.C. 23 24 /s/ Arthur M. Eidelhoch ARTHUR M. EIDELHOCH 25 AIMEE E. AXELROD 26 Attorneys for Defendants

[PROPOSED] ORDER

Good cause appearing.

IT IS HEREBY ORDERED that the Order Setting Initial Case Management Conference And ADR Deadlines be modified to continue the deadline for

1. Last day to "complete initial disclosures or state objection in Rule 26(f) Report" from October 9, 2012 to October 16, 2012. 7 8 9

20121026

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