STIPULATION AND [PROPOSED] ORDER REGARDING CONTINUANCE OF TRIAL DATE AND PRETRIAL DATES

RICHARD SEEBORG, District Judge.

STIPULATION

Pursuant to Civil Local Rules 40-1 and 7-12, the Plaintiff Camino Bell and Defendants John Muir Health, Angela Percival, and Sara Monahan (hereafter collectively referred to as "the Parties"), through their attorneys of record, hereby jointly stipulate and request a continuance of the current trial date of February 27, 2017, to May 8, 2017 or a date thereafter convenient to the Court based on the good cause set forth below.

Plaintiff's Complaint was filed on October 2, 2015 in the above-entitled court. A case management conference was held on January 21, 2016. As stated in their Joint Case Management Statement filed on January 14, 2016, the parties are amenable to private mediation, and agreed to schedule and complete the agreed upon ADR by August 5, 2016. The discovery cut-off deadline in the case is August 26, 2016. The trial date for this action is presently set for February 27, 2017. There has been no prior continuance of the trial date in this matter.

The parties have engaged in initial written discovery, and have been diligently working on completing the same. However, trial counsel for the parties (James Rosen, Elizabeth Bradley, Michael Bruno, and Hieu Tran) are also counsel in another pending matter entitled Perez, et al. v. John Muir Health, et al., Case No. 15-01792 HSG. The trial and discovery schedule in the Perez matter has been drawn out, impacting counsels' ability meet ongoing demands of discovery and trial preparation for this case. This is particularly true because the Perez matter involves a common defendant (John Muir Health), and several of the same key witnesses as the instant action. The trial in the Perez matter has been continued to August 22, 2016, which will render it difficult to schedule and complete all necessary depositions in this action.

The parties believe that a trial continuance, and a continuance of all dates leading up to the trial, would substantially assist the parties in completing fact discovery, and to participate meaningfully in ADR.

After having engaged in meet and confer discussions and subject to the approval of this Court, the parties have agreed to continue the trial date and have all dates, including discovery and motion deadlines, as follows:

[PROPOSED] ORDER

Having considered the Parties' Joint Stipulation to Continue Trial Date, Pretrial Conference, and Certain Pretrial Deadlines, as well as the Court's schedule, the Court hereby continues the Trial dates and all Pretrial dates as requested.

PURSUANT TO STIPULATION, IT IS SO ORDERED.