June 17, 2013
UNITED STATES OF AMERICA, STATE OF CALIFORNIA, ex rel. DR. JOHN MAA, et al., Plaintiff and Relator,
DR. JAMES W. OSTROFF, et al., Defendants.
IRELL & MANELLA LLP, John C. Hueston, (164921), Brian Hennigan, (86955), Eric J. Hayden, (254107), Newport Beach, California, Attorneys for Defendants.
KATHRYN BURKETT DICKSON, (70636), EMILY A. NUGENT, (255048), DICKSON GEESMAN LLP, Oakland, California.
David K. Colapinto, D.C. Bar #416390, Admitted Pro Hac Vice, KOHN, KOHN & COLAPINTO, LLP, Washington, D.C., Attorneys for Plaintiff-Relator.
JOINT STIPULATION TO EXTEND DEADLINES TO EXCHANGE INITIAL DISCLOSURES PURSUANT TO FED. R. CIV. P. 26
JOSEPH C. SPERO, District Judge.
THE PARTIES HEREBY STIPULATE AS FOLLOWS:
1) The parties have conferred and agree that because of Defendants' pending motion to dismiss the Second Amended Complaint, an extension of time is appropriate for the parties to exchange initial disclosures as required by Federal Rule of Civil Procedure 26.
2) The parties agree that the time to make initial disclosures is extended as follows: the parties will make initial discovery disclosures 30 days after the Court issues a ruling on the pending Motion to Dismiss Second Amended Complaint filed by Defendants. However, if the Court grants Defendants' motion to dismiss and gives Plaintiff leave to file an amended complaint, the parties' initial disclosures will be due 30 days after Plaintiff serves an amended complaint on Defendants.
3) This stipulation will not alter the date of any deadline already fixed by Court order. See Local Rule 6-1(a).
IT IS SO STIPULATED.
L.R. 5-1(i) ATTESTATION
I, Eric Hayden, am the ECF user whose ID and password are being used to file the parties' JOINT STIPULATION TO EXTEND DEADLINES TO EXCHANGE INITIAL DISCLOSURES PURSUANT TO FED. R. CIV. P. 26. In compliance with Local Rule 5-1(i), I hereby attest that David K. Colapinto, counsel for Plaintiff-Relator, has concurred in this filing.