May 16, 2013
HUIMIN SONG, Plaintiff,
COUNTY OF SANTA CLARA; SANTA CLARA VALLEY MEDICAL CENTER; PAUL ESTESS, ANNA HUGHES; and Does 1 through 70, Defendants.
ORRY P. KORB, County Counsel, JOHN L. WINCHESTER, III, Deputy County Counsel, OFFICE OF THE COUNTY COUNSEL San Jose, California Attorneys for Defendants COUNTY OF SANTA CLARA and Its Santa Clara Valley Medical Center, PAUL ESTESS AND ANNA HUGHES
LAW OFFICES OF BONNER & BONNER, CHARLES A. BONNER, ESQ., Attorney for Plaintiff, HUIMIN SONG.
AMENDED STIPULATION AND ORDER ENLARGING TIME FOR DEFENDANTS TO RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT AND CONTINUANCE OF CASE MANAGEMENT CONFERENCE
RONALD M. WHITE, District Judge.
The parties, through their respective counsel of record, hereby stipulate and agree to an order enlarging time, until June 16, 2013, for Defendants County of Santa Clara and its Santa Clara Valley Medical Center, Paul Estess and Anna Hughes to file and serve a response to the First Amended Complaint of Plaintiffs Huimin Song. The First Amended Complaint was served on March 13, 2013.
Good cause exists for this enlargement of time (30 additional days). Song and the County of Santa Clara are involved in litigation in the matter of Huimin Song and Andy Xie v. County of Santa Clara, Santa Clara Valley Medical Center, et. al., Case No. CV11-04450, pending before United States District Judge Edward J. Davila. The parties have been engaged in private mediation since January 16, 2013 with mediator Kael Briski of the Briski Mediation Group. Since the initial mediation on January 16, the parties and Mr. Briski have had countless email communications, two face to face discussions and no less than twelve phone conferences. Settlement demands, offers and terms of resolution have been exchanged. The parties are in the process of scheduling another mediation session on Friday, May 17, 2013 at 9:30 a.m. The settlement discussions have involved resolution of all issues, including the allegations giving rise to this lawsuit, between Song and the County. In view of the time and effort that will be necessary to prepare an appropriate responsive pleading, and the impending mediation session which the parties are hopeful will end both lawsuits, the parties respectfully request an order enlarging Defendants time to respond to the First Amended Complaint. Furthermore, the parties request that the Case Management Conference be continued to Friday, June 28, 2013, 10:30 a.m.
I hereby attest that I have on file the holograph signature indicated by a "conformed" signature (/S/) within this e-filed document.
IT IS SO STIPULATED.
Defendants may have to and including June 16, 2013 by which to file and serve a response to Plaintiff's First Amended Complaint. The Case Management Conference is continued to June 28, 2013, 10:30a.m. The Joint Case Management Statement is to be filed no later than June 21, 2013.