October 10, 2013
KRISTINNA GROTZ, an individual, Plaintiff,
KAISER FOUNDATION HOSPITALS, INC., THE PERMANENTE MEDICAL GROUP, INC., SEIU-UNITED HEALTHCARE WORKERS WEST, Defendants.
Michele Ballard Miller, Kaherine L. Kettler, MILLER LAW GROUP, A Professional Corporation, San Francisco, CA, Attorneys for Defendant, KAISER FOUNDATION HOSPITALS.
Bruce A. Harland, Manuel A. Boigues, WEINBERG, ROGER & ROSENFELD, Alameda, CA, Attorneys for Defendant, SEIU, UHW-WEST.
George F. Camerlengo, CAMERLENGO & JOHNSON, Redwood City, CA, Attorneys for Plaintiff, KRISTINNA GROTZ.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE DEADLINES SET IN THE COURT'S CASE MANAGEMENT AND PRETRIAL ORDER FOR JURY TRIAL FILED MAY 10, 2013 PURSUANT TO LOCAL RULE 6-2(a)
EDWARD M. CHEN, District Judge.
Pursuant to United States District Court of the Northern District of California's Local Rule ("Local Rule") 6-2(a), Plaintiff Kristinna Grotz ("Plaintiff") Defendant Kaiser Foundation Hospitals ("Kaiser") and SEIU-United Healthcare Workers West ("SEIU") (collectively the "Parties"), by and through their respective counsel of record, hereby stipulate to revise the Court's Case Management and Pretrial Order for Jury Trial as follows:
WHEREAS, on May 10, 2013 the Court filed a Case Management and Pretrial Order for Jury Trial in this case;
WHEREAS, the Parties have not previously sought to continue or extend any of the deadlines set by the Court's Case Management and Pretrial Order;
WHEREAS, the Parties are engaged in discovery and require additional time to complete key depositions and discovery in this case; and
WHEREAS, the Parties seek the opportunity to engage in further settlement negotiations after the completion of the key depositions.
IT IS HEREBY STIPULATED AND AGREED by and between the Parties, by and through their respective undersigned attorneys of record, that, pursuant to Local Rule 6-2(a), and having met and conferred regarding their respective calendars and availability, that the dates set by the Case Management and Pretrial Order be continued, as follows:
Event Current Date New Date File Updated Joint Status October 3, 2013 December 2, 2013 Report Further Status Conference October 25, 2013 December 5, 2013 Last Day to Serve Written October 29, 2013 February 28, 2014 Discovery (by hand) Fact Discovery Cut off November 28, 2013 March 31, 2014 Expert Reports Due November 28, 2013 March 31, 2014 Last Day to Serve (by hand December 10, 2013 April 14, 2014 expert related discovery Rebuttal Expert Reports December 19, 2013 April 25, 2014 Expert Discovery cut off January 9, 2014 May 9, 2014 Last date for motion hearing February 20, 2014 June 23, 2014 Trial and all related dates May 19, 2014 Push four months (or as Court can scheduled)
IT IS SO STIPULATED:
Having reviewed the Stipulation executed by Plaintiff KRISTINNA GROTZ, Defendant KAISER FOUNDATION HOSPITALS and Defendant SEIU-UNITED HEALTHCARE WORKERS WEST and good cause appearing, the Court hereby orders that the dates set by the Case Management and Pretrial Order be continued, as follows:
Event New Date File Updated Joint Status Report December 2, 2013 Further Status Conference December 5, 2013 Last Day to Serve Written Discovery (by February 28, 2014 hand) Fact Discovery Cut off March 31, 2014 Expert Reports Due March 31, 2014 Last Day to Serve (by hand expert related April 14, 2014 discovery Rebuttal Expert Reports April 25, 2014 Expert Discovery cut off May 9, 2014 Last date for motion hearing June 23, 2014 Trial and all related dates
PURSUANT TO STIPULATION, IT IS SO ORDERED.