Stipulation and Order

Cal. Super. - 6th Dist.March 2, 2021

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21 CV378996 Santa Clara - Civil on 7/2/2021 9:24 AM Reviewed B : R. Burciaga Case #21CV 78996 Envelope: 6773170 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP A Limited Liability Partnership Including Professional Corporations RICHARD J. SIMMONS, SBN 72666 rsimmonséDsheppardmullin.com R. Bur JASON W. KEARNAGHAN, SBN 207707 ikeamaghan(a)sheppardmullin.com HILARY A. HABIB, SBN 293431 hhabibGDsheppardmullin.com Filed 333 South Hope Street, 43rd Floor Los Angeles, California 90071-1422 Ju'y 7’ 2021 MELANIE M. HAMILTON, SBN 268037 Clerk 9f the Court mhamilton@sheppardmullin.com SUPGI‘IOF Court Of CA 650 Town Center Drive, 10th Floor County Of Santa Clara Costa Mesa, California 92626 21 CV378996 By: raragonAttorneys for Defendants BREANN D.H. CORTES SBN Email: bree@bdhclegal.com 12393 Sunnyglen Drive Moorpark, CA 93021 Attorneys for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA - DOWNTOWN SUPERIOR COURT VANESSA PAGADUAN, an individual, CASE NO.: 21CV378996 [Unlimited Jurisdiction] Plaintiff, JOINT STIPULATION TO CONTINUE V- HEARING DATE ON CASE MANAGEMENT CONFERENCE; HCA MANAGEMENT SERVICES, L.P., -[-PR9PGSEBi-ORDER a Delaware limited partnership; HCA-CALIFORNIA URGENT CARE HOLDINGS, LLC, a California limited $113425: fig 13= 2021 liability company; HCA HEALTHCARE, DEPT; 7' pm INC., a Delaware corporation; HCA HEALTH SERVICES OF CALIFORNIA, Complaint Filed; March 2’ 2021 INC., a California corporation; Trial Date: None HCA HEALTH SERVICES OF TENNESSEE, INC., a Tennessee corporation; and DOES 1- 1 00, inclusive, Defendants. ARBITRATION; [-PRGPG-SEB] ORDER :iaga 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO THE COURT AND TO ALL PARTIES AND TO THEIR RESPECTIVE COUNSEL OF RECORD: IT IS HEREBY STIPULATED and agreed by and between Plaintiff VANESSA PAGADUAN (“Plaintiff”) and Defendants HCA MANAGEMENT SERVICES, L.P., HCA-CALIFORNIA URGENT CARE HOLDINGS, LLC, HCA HEALTH SERVICES OF CALIFORNIA, INC., and HCA HEALTH SERVICES OF TENNESSEE, INC., (“Defendants”) (collectively, the “Parties”), through their respective counsel 0f record, t0 continue the hearing reserved for Case Management Conference and any related filing deadlines t0 a date mutually convenient for the Court 0n 0r after July 27, 2021. WHEREAS, on March 2, 2021, Plaintiff filed a Complaint against Defendants in the Superior Court 0f the State of California, County of Santa Clara, Case N0. 21CV378996; WHEREAS, 0n May 5, 2021, Defendants filed their Answer t0 the Complaint. WHEREAS, neither of the Parties received any notice from the Court in relation to this Case Management Conference and respectfully request an extension for time t0 prepare further. WHEREAS, the Parties have agreed t0 continue the July 13, 2021, Case Management Conference t0 July 27, 2021, 0r t0 a date thereafter that is convenient for the Court, Which will also continue any and all related filing deadlines per the California Code 0f Civil Procedure; WHEREAS, this Stipulation is not entered into with the intent to delay, but rather to allow the Parties t0 dedicate time and resources towards preparation as well as more time to discuss settlement. By continuing the hearing, there Will be n0 prejudice t0 any party in the case. The Parties have not previously sought a hearing continuance in this matter and the interests ofjustice are best served by a continuance. THEREFORE, subject t0 this Court’s approval, THE PARTIES HEREBY STIPULATE to an Order by the Court as follows: 1. The Case Management Conference, which is currently scheduled for July 13, 2021 at 2:15 pm in Department 7 0f the above-captioned Court, shall be continued t0 July 27, ARBITRATION; [PROPOSED] ORDER FP 3977961 7.2 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2021 at 2:15 pm in Department 7 of the above-captioned Court, 0r t0 a date thereafter that is convenient for the Court. 2. A11 filing deadlines shall be continued and consistent with the California Code 0f Civil Procedure and the new hearing date. DATE: July 1, 2021 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP /s/ Hilar‘yHabd)’ HILARY HABIB Attorneys for Defendants. DATE: July 1, 2021 /5r/BreavaH CorteA/ By: Breann D.H. Cortes, Esq. Attorneys for Plaintiff SANDI WEBB JOINT STIPULATION TO CONTINUE HEARING DATE ON CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 WORDER The Court, having reviewed the Parties’ Joint Stipulation, orders as follows: 1. The Parties’ Stipulation is approved. 2. The Case Management Conference shall be continued from July 13, 2021 to Julv 27 at 2:15 )QCM./P.M. in Department 7 0f the above- captioned Court. 3. A11 filing deadlines related t0 this conference are continued and consistent With the California Code of Civil Procedure and the new hearing date. DATED: JU'Y 2’ 2021 By; @21% Judge 0f the Superior Court Christopher G. Rudy JOINT STIPULATION TO CONTINUE HEARING DATE ON CASE MANAGEMENT CONFERENCE; EPRGPGSEB] ORDER