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Walker v. Cnty. of Santa Clara

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
Nov 21, 2011
No. 10-CV-04668 RS (N.D. Cal. Nov. 21, 2011)

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


Summaries of

Walker v. Cnty. of Santa Clara

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
Nov 21, 2011
No. 10-CV-04668 RS (N.D. Cal. Nov. 21, 2011)
Case details for

Walker v. Cnty. of Santa Clara

Case Details

Full title:THRESSA WALKER, GEETA SINGH, M.D., AND KAI IHNKEN, M.D., Plaintiffs, v…

Court:UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

Date published: Nov 21, 2011

Citations

No. 10-CV-04668 RS (N.D. Cal. Nov. 21, 2011)