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Christine Deeths, An Individual v. Lucile

April 16, 2013

CHRISTINE DEETHS, AN INDIVIDUAL, PLAINTIFF(S),
v.
LUCILE SALTER PACKARD CHILDREN'S HOSPITAL AT STANFORD, A CALIFORNIA CORPORATION; JOHN STIRLING, JR., INDIVIDUALLY; CEDARS-SINAI MEDICAL CENTER, A CALIFORNIA NON-PROFIT CORPORATION; CHRISTOPHER HARRIS, INDIVIDUALLY; BAKERSFIELD MEMORIAL HOSPITAL, A CALIFORNIA CORPORATION; ANTHONY THOMAS, INDIVIDUALLY; LEGACY BEHAVIORAL SERVICES, INC., A CALIFORNIA CORPORATION; TARA CRUZ, AN INDIVIDUAL; EDDIE CRUZ, AN INDIVIDUAL; AND DOES 1 THROUGH 50, INCLUSIVE,
DEFENDANTS.



The opinion of the court was delivered by: Jennifer L. Thurston United States Magistrate Judge

THIRD STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT (Doc. 17) Plaintiff CHRISTINE DEETHS and defendant LUCILE PACKARD CHILDREN'S HOSPITAL AT STANFORD by and through their undersigned counsel, hereby agree and stipulate as follows:

WHEREAS, this case involves multiple legal issues, upon which the parties are in the process of meeting and conferring.

WHEREAS, the parties are meeting and conferring in an effort to resolve the disputed issues through possible voluntary dismissal of Defendant LUCILE PACKARD CHILDREN'S HOSPITAL AT STANFORD or a possible narrowing of the issues to be potentially raised in a Federal Rule of Civil Procedure 12(b) Motion, in order to spare the resources of the Court.

WHEREAS, the court's order dated March 19, 2013, on the parties' second stipulation noted 3 that no further extensions were allowed, as it was the parties' third stipulation and that no reason for the 4 extension was noted in the earlier stipulation. However, it was defendant CEDARS-SINAI MEDICAL 5

CENTER who had filed its third stipulation on March 19, 2013 and not defendant LUCILE PACKARD 6

CHILDREN'S HOSPITAL AT STANFORD. 7

WHEREAS, defendant LUCILE PACKARD CHILDREN'S HOSPITAL AT STANFORD had 8 only filed one prior stipulation at that time and its reasons for meeting and conferring were cited in the 9 letter to the Court provided simultaneously with the stipulation. Therefore, it is the understanding of the parties that the language in the March 19, 2013, order disallowing further extensions, was intended for defendant CEDARS-SINAI MEDICAL CENTER and inadvertently directed at defendant LUCILE PACKARD CHILDREN'S HOSPITAL AT STANFORD.

WHEREAS, the parties will conclude the meet and confer process on the issues in the next 8 days.

STIPULATION

THAT FOR GOOD CAUSE SHOWN, the parties have reached the following stipulation:

1. Pursuant to Federal Rule of Civil Procedure 6(b), the time for defendant LUCILE PACKARD CHILDREN'S HOSPITAL AT STANFORD to respond to plaintiff Christine Deeths' Complaint for Damages is hereby extended by 7 days.

2. The new deadline to file a response to the complaint is now April 23, 2013. IT IS SO STIPULATED.

Dated: April 15, 2013 SHEUERMAN, MARTINI, TABARI, ZENERE & GARVIN By: /s/ Monique Shamun-Khasho, Esquire DAVID SHEUERMAN MONIQUE SHAMUN-KHASHO Attorneys for Defendant LUCILE PACKARD CHILDREN'S HOSPITAL AT STANFORD Dated: April 15, 2013 THE LAW OFFICES OF SHAWN A. McMILLAN, APC 2 3 By: /s/ Shawn A. McMillan, Esquire (as ...


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