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Santa Clara— Civil
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4H.Burciaga
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EFS-GZQ
ATTORNEY 0R PARTYWITHOUT MTORNEY: 250709
STATE BAR No; ElectronicdwufiiinI-Y
NAME
Angéifaaifidsngavflp by Superior Court of CA,
FIRM NAME:
STREETADDRESS,560 Mission Street, Suite 3100 C°unty °f 33m? Clara’
cm; San Francisco sTATE:CA ZIPCODE: 94105 on 6/1 9/2019 10'53 AN!
.TELEPHONEN0,:(415) 397-2823 mm; (415) 397-8549 ReVIewed By: R. BurCIaga
E.MAIL ADDRESS; abednarova@seyfarth.com Case #1 7CV309032
Kaiser Foundation Hospitals
ATrORNEY FORLnama): nvelope: 30271 03
SUPERIOR COURT 0F CALIFORNIA, COUNTY OE SANTA CLARA
STREETADDREss; 191 N. First Street
MAILING ADDRESS:
.1
cmANDZIpcone: San Jose, CA 95113 ..
'"
amcfime Downtown Superior Court (DTS) ,cAsE NUMBER;
PLAINTIFFIPETITIONER: Andrei Belorousou
17CV309032
DEFENDANT/RESPONDENT: Kaiser Foundation Hospitals, et al.
””D'C'AWme
OTHER:
.. ..., . .
DEPT;
PROPOSED ORDER (COVER SHEET) 2
NOTE: This coverwsheet isto be used to electronically file and submit to the court a proposed order. The proposed order sent
must be in PDF format and must be attached to this cover sheet. ln addition. a version of the proposed
electronically to the court
order inan editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed
order inPDF format are filed.
1. Name of the party submitting the proposed order:
Defendant Kaiser Foundation Hospitals
proposed order:
2. Title of the
[Proposed] Order Granting Joint Stipulation to Modify Expert Discovery Deadlines
3. The proceeding to which the proposed order relatesis:
N/A
proceeding:
a. Description of
b.Date and time:.
c.Place:
4. The proposed order was served on the other partiesinthe case.
June 19, 2019
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Andrea Bednarova
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0R PRINT NAME)
(TYPE OR ATTORNEY)
(SIGNATURE 0F PARTY
lags 1 cf 2
Form AdoptedMandatory Use
for
Judicial Council ot California
PROPOSED ORDER (COVER SHEET) Cal. Rules of Court,
. .. rules 2.252, 3.1312
EFs-ozo [Rev.r=ebruary 1.20171 (EIGthonIC Flllng) ww.courts.ca.gov
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CASE NAME: CASE NUMBER:
Belorousou v. Kaiser Foundation Hospitals, et al. 17CV309032
PROOF OF ELECTRONIC SERVICE
PROPOSED ORDER
1.lam and not a party to this action.
at least 18 years old
a. My residence or business address is(specify):
560 Mission Street. 31 st Floor,San Francisco, CA 94105
b.My electronic service address iéi-(specify):
cangel@seyfarth.com
2. |electronically served the Proposed Order (Cover Sheet) with a proposed orderinPDF format attached. and a proposed orderin
an editable word-processing format as follows:
a. On (name ofperson served) (Ifthe person sen/ed is an attorney, the party orparties represented should also be stated):
Victoria L. Gutierrez, Esq. and Kyle A. Pruner, Esq., attorneys for Plaintiff
b. To (electronic service address of person served):
vgutierrez@bohmlaw.com and kpruner@bohmlaw.com
c. On (date): .
June ‘I
9,201 9
DElectronic service of the Proposed Order: (Cover Sheet) with the attached proposed order in PDF format and service of the
proposed order in an editable word-processing format on additional persons are described in an attachment.
ideclare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date:
June 19,201 9
Carolyn Angel
0R PRINT NAME 0F DECLARANT)
(TYPE
EFs—oza [RumFabeuarymmT]
PROPOSED ORDER (COVER SHEET) ”9’2“:
(Electronic Filing)
'
American Legnmet.
Inc. t
.mfihimmxkflamm .
_
SEYFARTH SHAW LLP
Christian J. Rowley (SBN 187293)
crowley@seyfarth.com
Andrea Bednarova (SBN 250709)
abednarova@seyfarth.com
560 Mission Street, 3 lst Floor
.p San Francisco, California 94105
Telephone: (415) 397-2823
Facsimile: (41 5) 397-8549
QQUI
Attorneys for Defendant
KAISER FOUNDATION HOSPITALS
SUPERIOR COURT OF THE STATE OF CALIFORNIA
1o
COUNTY OF SANTA CLARA
11
12
ANDREI BELOROUSOU, Case No. 17CV3 09032
13
Plaintiff, JOINT STIPULATION TO MODIFY
14 EXPERT DISCOVERY DEADLINES;
v.
15
Complaint Filed: April 24, 2017
16 KAISER FOUNDATION HOSPITALS; and FAC Filed: June 27, 2017
DOES 1 through 50, inclusive, -
SAC Filed: November 2, 1017
17 Trial Date: August 19, 201 9
Defendants.
18
19
20
21
STIPULATION
Plaintiff Andrei Belorousou and Defendant Kaiser Foundation Hospitals, by and through their
22
respective counsel ofrecord, agree and stipulate as follows:
23
24 WHEREAS, the trial in this matter is set tobegin on August 19, 201 9.
25 WHEREAS, the deadline for expert Witness disclosures isJuly 1, 2019.
26 WHEREAS, the parties have previously stipulated to advance the date of the Mandatory
Settlement Conference to July 3, 201 9, t0 attempt to resolve the case before incurring significant trial
27
preparation expenses.
28
JOINT STIPULATION TO MODIFY EXPERT DISCOVERY DEADLINES; [PROPOSED] ORDER
57576284v.1
WHEREAS, the parties agree on the following expert discovery deadlines to occur after the
Mandatory Settlement Conference 0n July 3, 201 9:
July 10, 2019 Date of expert Witness disclosures, served electronically, with a courtesy
copy served Via U.S. Mail.
July 24, 2019 Date of supplemental expert witness disclosures, served electronically,
With a courtesy copy served Via U.S. Mail.
August 12, 2019 Expert discovery cutoff. The parties W111 accept service of deposition
notices and subpoenas to their experts electronically.
August 15, 2019 Expert discovery motion hearing cutoff.
10 IT IS SO STIPULATED.
11
12 DATED: June 18, 2019 SEYFARTH SHAW LLP
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13
14
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By:
Christian J. Rowley
15 Andrea Bednarova
Attorneys for Defendant
16 KAISER FOUNDATION HOSPITALS
17
18
19
20
DATED: June ,
2019 BOHM LAW GROUP, INC.
j
21
22
Victoria Gutierrez, Esq.
23 Kyle Pruner, Esq.
Attorneys for Plaintiff
24
ANDREI BELOROUSOU
25
26
27
28
2
I
.JOIN'I‘STIPULATION TO MODIFY EXPERT DISCOVERY DEADLINES; [PROPOSED] ORDER
57576284v.1
[PR OSED] ORDER
N Pursuant to the parties’ Stipulation to Modify Expert Discovery Deadlines, and good cause
AU.)
appearing, IT IS ORDERED THAT:
The expert discovery schedule is modified as follows:
July 10, 2019 Date of expert witness disclosures, served electronically, with a courtesy
copy served Via U.S. Mail.
\OOONQUI
July 24, 2019 Date of supplemental expert witness disclosures, served electronically,
with a courtesy copy served via U.S. Mail.
August 12, 2019 Expert discovery cutoff. The parties will accept service of deposition
10 notices and subpoenas to their experts electronically.
11 August 15, 2019 Expert discovery motion hearing cutoff.
12
so ORDERED.
1w
IT Is
M
13
14 JUN 2 0 2019
15 DATED: ,2019
Judge of the Supqrior Court
16. Mark H. Flam
17
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3
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JOINT S'IIPULATION TO MODIFY EHERT DISCOVERY DEADLINES; [PROPOSED] ORDER
57576284v.1
Preview
lIUVOUUUOA Santa Clara— Civil u: 4H.Burciaga I EFS-GZQ ATTORNEY 0R PARTYWITHOUT MTORNEY: 250709 STATE BAR No; ElectronicdwufiiinI-Y NAME Angéifaaifidsngavflp by Superior Court of CA, FIRM NAME: STREETADDRESS,560 Mission Street, Suite 3100 C°unty °f 33m? Clara’ cm; San Francisco sTATE:CA ZIPCODE: 94105 on 6/1 9/2019 10'53 AN! .TELEPHONEN0,:(415) 397-2823 mm; (415) 397-8549 ReVIewed By: R. BurCIaga E.MAIL ADDRESS; abednarova@seyfarth.com Case #1 7CV309032 Kaiser Foundation Hospitals ATrORNEY FORLnama): nvelope: 30271 03 SUPERIOR COURT 0F CALIFORNIA, COUNTY OE SANTA CLARA STREETADDREss; 191 N. First Street MAILING ADDRESS: .1 cmANDZIpcone: San Jose, CA 95113 .. '" amcfime Downtown Superior Court (DTS) ,cAsE NUMBER; PLAINTIFFIPETITIONER: Andrei Belorousou 17CV309032 DEFENDANT/RESPONDENT: Kaiser Foundation Hospitals, et al. ””D'C'AWme OTHER: .. ..., . . DEPT; PROPOSED ORDER (COVER SHEET) 2 NOTE: This coverwsheet isto be used to electronically file and submit to the court a proposed order. The proposed order sent must be in PDF format and must be attached to this cover sheet. ln addition. a version of the proposed electronically to the court order inan editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed order inPDF format are filed. 1. Name of the party submitting the proposed order: Defendant Kaiser Foundation Hospitals proposed order: 2. Title of the [Proposed] Order Granting Joint Stipulation to Modify Expert Discovery Deadlines 3. The proceeding to which the proposed order relatesis: N/A proceeding: a. Description of b.Date and time:. c.Place: 4. The proposed order was served on the other partiesinthe case. June 19, 2019 . ¢ v {- fl. r’ {W m WM fl /} ’ 1 Andrea Bednarova ‘ P 0R PRINT NAME) (TYPE OR ATTORNEY) (SIGNATURE 0F PARTY lags 1 cf 2 Form AdoptedMandatory Use for Judicial Council ot California PROPOSED ORDER (COVER SHEET) Cal. Rules of Court, . .. rules 2.252, 3.1312 EFs-ozo [Rev.r=ebruary 1.20171 (EIGthonIC Flllng) ww.courts.ca.gov Anw'fiu'njmlmt. Int I V- . .pmavgt‘amlomitem _ ‘ EFS-OZO CASE NAME: CASE NUMBER: Belorousou v. Kaiser Foundation Hospitals, et al. 17CV309032 PROOF OF ELECTRONIC SERVICE PROPOSED ORDER 1.lam and not a party to this action. at least 18 years old a. My residence or business address is(specify): 560 Mission Street. 31 st Floor,San Francisco, CA 94105 b.My electronic service address iéi-(specify): cangel@seyfarth.com 2. |electronically served the Proposed Order (Cover Sheet) with a proposed orderinPDF format attached. and a proposed orderin an editable word-processing format as follows: a. On (name ofperson served) (Ifthe person sen/ed is an attorney, the party orparties represented should also be stated): Victoria L. Gutierrez, Esq. and Kyle A. Pruner, Esq., attorneys for Plaintiff b. To (electronic service address of person served): vgutierrez@bohmlaw.com and kpruner@bohmlaw.com c. On (date): . June ‘I 9,201 9 DElectronic service of the Proposed Order: (Cover Sheet) with the attached proposed order in PDF format and service of the proposed order in an editable word-processing format on additional persons are described in an attachment. ideclare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: June 19,201 9 Carolyn Angel 0R PRINT NAME 0F DECLARANT) (TYPE EFs—oza [RumFabeuarymmT] PROPOSED ORDER (COVER SHEET) ”9’2“: (Electronic Filing) ' American Legnmet. Inc. t .mfihimmxkflamm . _ SEYFARTH SHAW LLP Christian J. Rowley (SBN 187293) crowley@seyfarth.com Andrea Bednarova (SBN 250709) abednarova@seyfarth.com 560 Mission Street, 3 lst Floor .p San Francisco, California 94105 Telephone: (415) 397-2823 Facsimile: (41 5) 397-8549 QQUI Attorneys for Defendant KAISER FOUNDATION HOSPITALS SUPERIOR COURT OF THE STATE OF CALIFORNIA 1o COUNTY OF SANTA CLARA 11 12 ANDREI BELOROUSOU, Case No. 17CV3 09032 13 Plaintiff, JOINT STIPULATION TO MODIFY 14 EXPERT DISCOVERY DEADLINES; v. 15 Complaint Filed: April 24, 2017 16 KAISER FOUNDATION HOSPITALS; and FAC Filed: June 27, 2017 DOES 1 through 50, inclusive, - SAC Filed: November 2, 1017 17 Trial Date: August 19, 201 9 Defendants. 18 19 20 21 STIPULATION Plaintiff Andrei Belorousou and Defendant Kaiser Foundation Hospitals, by and through their 22 respective counsel ofrecord, agree and stipulate as follows: 23 24 WHEREAS, the trial in this matter is set tobegin on August 19, 201 9. 25 WHEREAS, the deadline for expert Witness disclosures isJuly 1, 2019. 26 WHEREAS, the parties have previously stipulated to advance the date of the Mandatory Settlement Conference to July 3, 201 9, t0 attempt to resolve the case before incurring significant trial 27 preparation expenses. 28 JOINT STIPULATION TO MODIFY EXPERT DISCOVERY DEADLINES; [PROPOSED] ORDER 57576284v.1 WHEREAS, the parties agree on the following expert discovery deadlines to occur after the Mandatory Settlement Conference 0n July 3, 201 9: July 10, 2019 Date of expert Witness disclosures, served electronically, with a courtesy copy served Via U.S. Mail. July 24, 2019 Date of supplemental expert witness disclosures, served electronically, With a courtesy copy served Via U.S. Mail. August 12, 2019 Expert discovery cutoff. The parties W111 accept service of deposition notices and subpoenas to their experts electronically. August 15, 2019 Expert discovery motion hearing cutoff. 10 IT IS SO STIPULATED. 11 12 DATED: June 18, 2019 SEYFARTH SHAW LLP x 13 14 r iwéi'fx?’ w {gww MN f ,f’ i By: Christian J. Rowley 15 Andrea Bednarova Attorneys for Defendant 16 KAISER FOUNDATION HOSPITALS 17 18 19 20 DATED: June , 2019 BOHM LAW GROUP, INC. j 21 22 Victoria Gutierrez, Esq. 23 Kyle Pruner, Esq. Attorneys for Plaintiff 24 ANDREI BELOROUSOU 25 26 27 28 2 I .JOIN'I‘STIPULATION TO MODIFY EXPERT DISCOVERY DEADLINES; [PROPOSED] ORDER 57576284v.1 [PR OSED] ORDER N Pursuant to the parties’ Stipulation to Modify Expert Discovery Deadlines, and good cause AU.) appearing, IT IS ORDERED THAT: The expert discovery schedule is modified as follows: July 10, 2019 Date of expert witness disclosures, served electronically, with a courtesy copy served Via U.S. Mail. \OOONQUI July 24, 2019 Date of supplemental expert witness disclosures, served electronically, with a courtesy copy served via U.S. Mail. August 12, 2019 Expert discovery cutoff. The parties will accept service of deposition 10 notices and subpoenas to their experts electronically. 11 August 15, 2019 Expert discovery motion hearing cutoff. 12 so ORDERED. 1w IT Is M 13 14 JUN 2 0 2019 15 DATED: ,2019 Judge of the Supqrior Court 16. Mark H. Flam 17 18 19 20 21 22 23 24 25 26 27 28 3 I JOINT S'IIPULATION TO MODIFY EHERT DISCOVERY DEADLINES; [PROPOSED] ORDER 57576284v.1