Opinion
No. 10-CV-04668 RS
11-21-2011
THRESSA WALKER, GEETA SINGH, M.D., AND KAI IHNKEN, M.D., Plaintiffs, v. COUNTY OF SANTA CLARA, SANTA CLARA VALLEY MEDICAL CENTER, HOLLISTER BREWSTER, M.D., ALFONSO BANUELOS, M.D., DOLLY GOEL, M.D., AND DOES 1 through 50, inclusive, Defendants.
CHARLES A. BONNER, ESQ. SB# 85413 A. CABRAL BONNER, ESQ. SB# 247528 LAW OFFICES OF BONNER & BONNER 475 GATE FIVE RD. SUITE 212 ATTORNEYS FOR PLAINTIFFS
CHARLES A. BONNER, ESQ. SB# 85413
A. CABRAL BONNER, ESQ. SB# 247528
LAW OFFICES OF BONNER & BONNER
475 GATE FIVE RD. SUITE 212
ATTORNEYS FOR PLAINTIFFS
STIPULATION TO FILE FOURTH AMENDED COMPLAINT AND [PROPOSED ORDER] AS MODIFIED BY THE COURT
IT IS HEREBY STIPULATED AND AGREED by the parties, through their respective attorneys of record, that the Court may grant Plaintiffs leave to file a Fourth Amended Complaint to incorporate new allegations respecting events that took place after Plaintiffs filed their Third Amended Complaint.
Plaintiffs contend that good cause exists for this further amended pleading incorporating new allegations that arise out of a common nucleus of operative facts as in Plaintiffs' original and amended complaints. A copy of Plaintiff's proposed Fourth Amended Complaint is attached as Stipulation to File Fourth Amended Complaint Exhibit A, and the new allegations are italicized and set forth in Paragraphs 120.1 through 120.55, and 285 through 290.
It is further stipulated that Defendants shall have 30 days from the filing of the Fourth Amended Complaint to respond to that Fourth Amended Complaint, and such response(s) need only address those new allegations as identified in the above-referenced numbered paragraphs.
I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/S/) within this efiled document.
LAW OFFICES OF
BONNER& BONNER
A.CABRAL BONNER
Attorney for Plaintiffs
MIGUEL MARQUEZ
County Counsel
GREGORY J. SEBASTINELLI
Deputy County Counsel
Attorneys for Defendants
[PROPOSED] ORDER
IT IS HEREBY ORDERED that Plaintiffs may file a Fourth Amended Complaint in the form attached hereto as Exhibit A. Defendants shall have 30 days from the filing of the Fourth Amended Complaint to respond to it, and such response(s) need only address those new allegations as identified in Paragraphs 120.1 to 120.55 and 285 to 290.
HONORABLE RICHARD SEEBORG
United States District Court Judge