United States District Court, N.D. California, San Francisco Division
XEROX CONSULTANT COMPANY, INC., a Michigan corporation, Plaintiff,
MARIN GENERAL HOSPITAL CORPORATION, a California non-profit public benefit corporation, Defendant. AND RELATED COUNTERCLAIM
ARCHER NORRIS, P.C. Douglas C. Straus, Sharon C. Collier, Walnut Creek, CA, Attorneys for Defendant and Counter-Claimant, MARIN GENERAL HOSPITAL CORPORATION.
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP A Limited Liability Partnership Including Professional Corporations PHILIP F. ATKINS-PATTENSON, ARTHUR J. FRIEDMAN, San Francisco, California, Attorneys for Plaintiff and Counter-Defendant XEROX CONSULTANT COMPANY, INC.
STIPULATED REQUEST FOR ORDER CHANGING TIME TO CONTINUE TRIAL AND PRE-TRAIL DATES JOINT DECLARATION [PROPOSED] ORDER
JOINT DECLARATION [PROOOSED] ORDER
EDWARD M. CHEN, District Judge.
Pursuant to Civ. L.R. 6-2(a) and 7-12, Defendant and Counter-Claimant Marin General Hospital Corporation ("MGHC") and Plaintiff and Counter-Defendant Xerox Consulting Company, Inc. ("Xerox"), by and through their attorneys of record, respectfully submit their Stipulated Request For Order Changing Time To Continue Trial And Pretrial Dates.
STIPULATED JOINT REQUEST
In support thereof, the parties state the following:
1. At the Status Conference on June 6, 2013, the Court set the schedule for the case. (Dkt. # 36.) Among other dates, March 6, 2014 is the last date for completion of non-expert discovery and the date for exchange of expert reports.
2. At the Status Conference on December 12, 2013, the Court did not modify the case schedule, directed the parties to "accelerate the discovery process, " referred the case to a Magistrate Judge for discovery, and extended the date for completion of mediation to February 28, 2014. (Dkt. # 43.) Magistrate Judge Cousins was appointed to handle discovery.
3. Since the Status Conference on December 12, 2014:
a. The parties finalized and the Court entered the Stipulated Protective Order on December 18, 2013. (Dkt. # 45.) Entry of the Stipulated Protective Order was necessary for the parties' document productions to begin as they contain data and information covered by HIPAA.
b. On December 27, 2013, Xerox made an initial production to MGHC of almost 50, 000 unique records in electronic form.
c. On January 22, 2014, MGHC has made an initial production to Xerox of more than 290, 000 unique records in electronic form.
d. On January 13, 2014, the parties' submitted their Joint Report on Discovery to Judge Cousins. (Dkt. # 46.)
e. On January 16, 2014, the parties attended the initial Discovery Conference before ...