Preview
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222022
Michele Ballard Miller (SBN 104198)
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mbmiller@cozen.com
Elena K. Hillman (SBN 157337) .
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ehillman@cozen.com FILED
COZEN O'CONNOR
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101 Montgomery Street, Suite 1400 ALAMEDA COUNTY
San Francisco, CA 9410 Jui: om
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Telephone: Cr Ns 4 1013 0 2021
Facsimile: (415) 644- CLERK OF THE SUPERIOR COURT
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for Defendant ew ae, Ae Lea
Attorneys
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THE PERMANENTE MEDICAL GROUP,
INC.
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF ALAMEDA -
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DONNA MCCLANE, Case No.: RG19014777
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Plaintiff, ASSIGNED FOR ALL PURPOSES TO
ST, Sure 1400
JUDGE Stephen Pulido
SAN FRANcIsSco, CA 94104
WH
ee
O'CONNOR
V. DEPARTMENT 517
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er
101 MonTGomEeRY
THE PERMANENTE MEDICAL GROUP, JOINT STIPULATION TO CONTINUE
COZEN
INC. a California corporation, d/;b/a Kaiser | TRIAL DATE AND ALL RELATED
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Permanente; and DOES 1-50, inclusive, PRETRIAL DATES AND REQUEST FOR
A TRIAL SETTING CONFERENCE AND
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Defendant. [PREFOSED] ORDER - AZ-vV/ LEWITTER MALKANI
101 Monroomery Sr, SuiTe 1400
Gx |b [o>
CA 94104
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O'CONNOR
SAN FRANCISCO,
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CozeNn
oaWeber
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Attorneys forPlaintiff
DONNA MCCLANE
ee
-Dated: June 21, 2021 COZEN O'CONNOR
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Tins. Konda, Yl
By:
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Elena Hillman
Attorneys for Defendant
DR
THE PERMANENTE MEDICAL
GROUP, INC.
PA
DN
PO
DN
PO
PR
PR
NM
4
JOINT STIPULATION TO CONTINUE TRIAL DATE AND ALL RELATED PRETRIAL DATES AND
REQUEST FOR TRIAL SETTING CONFERENCE; [PROPOSED] ORDER - Case No: RG19014777
11. Accordingly, to prevent prejudice to either Party, and to facilitate
=
further settlement efforts, the Parties STIPULATE and AGREE to vacate the trialdate of
DB
November 15, 2021, along with all pre-trial deadlines, including, but not limited to,
W
deadlines for the completion of discovery and the date for dispositive motions, and continue
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the trial date. Therefore, the Parties request that the Court schedule a trial setting
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conference to be set at such date and time as may be convenient for the Court. Defendant
DO
will not file a. Motion for Summary Judgement and/or Summary Adjudication until that time.
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Defendant may request a later hearing for a dispositive motion after the Court sets a new
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trialdate.
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Respectfully submitted,
Dated: June 21, 2021 —> LEWITTER MALKANI
101 Monroomery Sr, SuiTe 1400
Gx |b [o>
CA 94104
oe
O'CONNOR
SAN FRANCISCO,
ok
CozeNn
oaWeber
we
Attorneys forPlaintiff
DONNA MCCLANE
ee
-Dated: June 21, 2021 COZEN O'CONNOR
wd
Tins. Konda, Yl
By:
wd
Elena Hillman
Attorneys for Defendant
DR
THE PERMANENTE MEDICAL
GROUP, INC.
PA
DN
PO
DN
PO
PR
PR
NM
4
JOINT STIPULATION TO CONTINUE TRIAL DATE AND ALL RELATED PRETRIAL DATES AND
REQUEST FOR TRIAL SETTING CONFERENCE; [PROPOSED] ORDER - Case No: RG19014777
11. Accordingly, to prevent prejudice to either Party, and to facilitate
=
further settlement efforts, the Parties STIPULATE and AGREE to vacate the trialdate of
DB
November 15, 2021, along with all pre-trial deadlines, including, but not limited to,
W
deadlines for the completion of discovery and the date for dispositive motions, and continue
BF
the trial date. Therefore, the Parties request that the Court schedule a trial setting
oO
conference to be set at such date and time as may be convenient for the Court. Defendant
DO
will not file a. Motion for Summary Judgement and/or Summary Adjudication until that time.
nN
Defendant may request a later hearing for a dispositive motion after the Court sets a new
OA
trialdate.
oO
tk
Respectfully submitted,
Dated: June 21, 2021 —> LEWITTER MALKANI
101 Monroomery Sr, SuiTe 1400
Gx |b [o>
CA 94104
oe
O'CONNOR
SAN FRANCISCO,
ok
CozeNn
oaWeber
we
Attorneys forPlaintiff
DONNA MCCLANE
ee
-Dated: June 21, 2021 COZEN O'CONNOR
wd
Tins. Konda, Yl
By:
wd
Elena Hillman
Attorneys for Defendant
DR
THE PERMANENTE MEDICAL
GROUP, INC.
PA
DN
PO
DN
PO
PR
PR
NM
4
JOINT STIPULATION TO CONTINUE TRIAL DATE AND ALL RELATED PRETRIAL DATES AND
REQUEST FOR TRIAL SETTING CONFERENCE; [PROPOSED] ORDER - Case No: RG19014777
11. Accordingly, to prevent prejudice to either Party, and to facilitate
=
further settlement efforts, the Parties STIPULATE and AGREE to vacate the trialdate of
DB
November 15, 2021, along with all pre-trial deadlines, including, but not limited to,
W
deadlines for the completion of discovery and the date for dispositive motions, and continue
BF
the trial date. Therefore, the Parties request that the Court schedule a trial setting
oO
conference to be set at such date and time as may be convenient for the Court. Defendant
DO
will not file a. Motion for Summary Judgement and/or Summary Adjudication until that time.
nN
Defendant may request a later hearing for a dispositive motion after the Court sets a new
OA
trialdate.
oO
tk
Respectfully submitted,
Dated: June 21, 2021 —> LEWITTER MALKANI
101 Monroomery Sr, SuiTe 1400
Gx |b [o>
CA 94104
oe
O'CONNOR
SAN FRANCISCO,
ok
CozeNn
oaWeber
we
Attorneys forPlaintiff
DONNA MCCLANE
ee
-Dated: June 21, 2021 COZEN O'CONNOR
wd
Tins. Konda, Yl
By:
wd
Elena Hillman
Attorneys for Defendant
DR
THE PERMANENTE MEDICAL
GROUP, INC.
PA
DN
PO
DN
PO
PR
PR
NM
4
JOINT STIPULATION TO CONTINUE TRIAL DATE AND ALL RELATED PRETRIAL DATES AND
REQUEST FOR TRIAL SETTING CONFERENCE; [PROPOSED] ORDER - Case No: RG19014777
=
PH
WH
cause therefore, the Joint Stipulation is
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IT IS ORDERED as follows; A
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1. The trial date of Nove er 15, 2021 is vacated and the trial is continued to
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,2022.
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2. All deadlines refated to the trial date, including, but not limited to, all discovery
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deadlines and the deadine for the Court to hear motions for summary judgment, will be
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calculated based on Ahe new trialdate.
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3. A thal
setting conference is set for
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ITISSOORDERED. ~— A evi dD
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Dated: G. 24-292) CN _]
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Hon. Stephen Pukdo~\,
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JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED DEADLINES; AND [PROPOSED]
ORDER THEREON - Case No: RG19014777
=
PH
WH
cause therefore, the Joint Stipulation is
BR
IT IS ORDERED as follows; A
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1. The trial date of Nove er 15, 2021 is vacated and the trial is continued to
OD
,2022.
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2. All deadlines refated to the trial date, including, but not limited to, all discovery
Oa
deadlines and the deadine for the Court to hear motions for summary judgment, will be
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calculated based on Ahe new trialdate.
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3. A thal
setting conference is set for
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ITISSOORDERED. ~— A evi dD
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Dated: G. 24-292) CN _]
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Hon. Stephen Pukdo~\,
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JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED DEADLINES; AND [PROPOSED]
ORDER THEREON - Case No: RG19014777
=
PH
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cause therefore, the Joint Stipulation is
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IT IS ORDERED as follows; A
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1. The trial date of Nove er 15, 2021 is vacated and the trial is continued to
OD
,2022.
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2. All deadlines refated to the trial date, including, but not limited to, all discovery
Oa
deadlines and the deadine for the Court to hear motions for summary judgment, will be
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calculated based on Ahe new trialdate.
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3. A thal
setting conference is set for
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ITISSOORDERED. ~— A evi dD
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Dated: G. 24-292) CN _]
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Hon. Stephen Pukdo~\,
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JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED DEADLINES; AND [PROPOSED]
ORDER THEREON - Case No: RG19014777
=
PH
WH
cause therefore, the Joint Stipulation is
BR
IT IS ORDERED as follows; A
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1. The trial date of Nove er 15, 2021 is vacated and the trial is continued to
OD
,2022.
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2. All deadlines refated to the trial date, including, but not limited to, all discovery
Oa
deadlines and the deadine for the Court to hear motions for summary judgment, will be
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calculated based on Ahe new trialdate.
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3. A thal
setting conference is set for
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ITISSOORDERED. ~— A evi dD
HS
WO
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Dated: G. 24-292) CN _]
OTD
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Hon. Stephen Pukdo~\,
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DB
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JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED DEADLINES; AND [PROPOSED]
ORDER THEREON - Case No: RG19014777
Case Title: Ross v. Bayerische Motoren Werke
Case No. RG20-084475
CLERK’S CERTIFICATE OF MAILING
I certify that the following is true and correct:
Iam a Deputy Clerk employed by the Alameda County Superior Court. I am over the age of 18
years. My business address is 24405 Amador Street, Hayward, California. I served the ORDER
by placing copies in envelopes addressed as shown below and sealing and placing them for
collection, stamping or metering with prepaid postage, and mailing on the date stated below, in
the United States mail at Alameda County, California, following standard court practices.
Miller, Michele Lanzetta, Tobin M.
Cozen O'Coner Greene Broilet & Sheeler LLP
101 Montgomery Street Ste 1400 100 Wilshire Blvd. Ste 2100
San Francisco, CA 94104 Santa Monica, CA 90407-2131
Meyer, Steven E.
Lewis Brisbois Bisgaard & Smith LLP
633 West 5" Street Ste. 4000
Los Angeles, CA 90071
Dated: 06-30-21
Chad Finke
Executive Officer/Clerk of the Superior Court
By: zZ HL
Danielle Labrecgtte, Deputy Clerk |
Revised 3/29/2016
Case Title: Ross v. Bayerische Motoren Werke
Case No. RG20-084475
CLERK’S CERTIFICATE OF MAILING
I certify that the following is true and correct:
Iam a Deputy Clerk employed by the Alameda County Superior Court. I am over the age of 18
years. My business address is 24405 Amador Street, Hayward, California. I served the ORDER
by placing copies in envelopes addressed as shown below and sealing and placing them for
collection, stamping or metering with prepaid postage, and mailing on the date stated below, in
the United States mail at Alameda County, California, following standard court practices.
Miller, Michele Lanzetta, Tobin M.
Cozen O'Coner Greene Broilet & Sheeler LLP
101 Montgomery Street Ste 1400 100 Wilshire Blvd. Ste 2100
San Francisco, CA 94104 Santa Monica, CA 90407-2131
Meyer, Steven E.
Lewis Brisbois Bisgaard & Smith LLP
633 West 5" Street Ste. 4000
Los Angeles, CA 90071
Dated: 06-30-21
Chad Finke
Executive Officer/Clerk of the Superior Court
By: zZ HL
Danielle Labrecgtte, Deputy Clerk |
Revised 3/29/2016
Case Title: Ross v. Bayerische Motoren Werke
Case No. RG20-084475
CLERK’S CERTIFICATE OF MAILING
I certify that the following is true and correct:
Iam a Deputy Clerk employed by the Alameda County Superior Court. I am over the age of 18
years. My business address is 24405 Amador Street, Hayward, California. I served the ORDER
by placing copies in envelopes addressed as shown below and sealing and placing them for
collection, stamping or metering with prepaid postage, and mailing on the date stated below, in
the United States mail at Alameda County, California, following standard court practices.
Miller, Michele Lanzetta, Tobin M.
Cozen O'Coner Greene Broilet & Sheeler LLP
101 Montgomery Street Ste 1400 100 Wilshire Blvd. Ste 2100
San Francisco, CA 94104 Santa Monica, CA 90407-2131
Meyer, Steven E.
Lewis Brisbois Bisgaard & Smith LLP
633 West 5" Street Ste. 4000
Los Angeles, CA 90071
Dated: 06-30-21
Chad Finke
Executive Officer/Clerk of the Superior Court
By: zZ HL
Danielle Labrecgtte, Deputy Clerk |
Revised 3/29/2016
Case Title: Ross v. Bayerische Motoren Werke
Case No. RG20-084475
CLERK’S CERTIFICATE OF MAILING
I certify that the following is true and correct:
Iam a Deputy Clerk employed by the Alameda County Superior Court. I am over the age of 18
years. My business address is 24405 Amador Street, Hayward, California. I served the ORDER
by placing copies in envelopes addressed as shown below and sealing and placing them for
collection, stamping or metering with prepaid postage, and mailing on the date stated below, in
the United States mail at Alameda County, California, following standard court practices.
Miller, Michele Lanzetta, Tobin M.
Cozen O'Coner Greene Broilet & Sheeler LLP
101 Montgomery Street Ste 1400 100 Wilshire Blvd. Ste 2100
San Francisco, CA 94104 Santa Monica, CA 90407-2131
Meyer, Steven E.
Lewis Brisbois Bisgaard & Smith LLP
633 West 5" Street Ste. 4000
Los Angeles, CA 90071
Dated: 06-30-21
Chad Finke
Executive Officer/Clerk of the Superior Court
By: zZ HL
Danielle Labrecgtte, Deputy Clerk |
Revised 3/29/2016