Stipulation re VDRP; Order 1

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

JASON RABINOWITZ, SBN 183822 

COSTA KERESTENZIS, SBN 186125 

BEESON, TAYER & BODINE, APC. 

1001 – 6th Street, Suite 500 

Sacramento, CA 95814 

Telephone: 916.441.2196; 

Facsimile: 916.441.5208 

Attorneys for Plaintiff LINDA HARDY 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

LINDA HARDY, 

Plaintiff, 

v. 

HEALTH NET OF CALIFORNIA, INC., 

Defendant. 

Case No. Civ-S-04-1190 DFL PAN 

STIPULATION AND REQUEST FOR 

REFERRAL TO THE COURT’S 

VOLUNTARY DISPUTE RESOLUTION 

PROGRAM 

PURSUANT TO LOCAL RULES 16-271 AND 83-143, AND SUBJECT TO THE 

APPROVAL OF THIS COURT, the parties to the above-referenced action, through their 

undersigned counsel, hereby stipulate and respectfully request the referral of this case to the 

Court’s Voluntary Dispute Resolution Program. The parties have begun settlement discussions 

and believe that referral to VDRP will assist in resolving this matter. 

/// 

/// 

/// 

/// 

Case 2:04-cv-01190-DFL-PAN Document 18 Filed 05/12/05 Page 1 of 3
Stipulation re VDRP; Order 2

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 BEESON, TAYER & BODINE – APC 

Dated: /s/ Costa Kerestenzis 

 Costa Kerestenzis, 

 Attorneys for Plaintiff 

 LINDA HARDY 

 BALLARD, ROSENBERG, GOLPER & 

 SAVITT, LLP 

Dated: /s/ Wendy Moss 

 Wendy Moss, 

 Attorneys for Defendant 

 HEALTH NET, INC. 

IT IS SO ORDERED: 

Dated: 5/11/2005 ___/s/ David F. Levi________ 

 HON. DAVID F. LEVI 

 United States District Judge 

Case 2:04-cv-01190-DFL-PAN Document 18 Filed 05/12/05 Page 2 of 3
Stipulation re VDRP; Order 3

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

PROOF OF SERVICE 

STATE OF CALIFORNIA, COUNTY OF SACRAMENTO 

I declare that I am employed in the County of Sacramento, State of California. I am over 

the age of eighteen (18) years and not a party to the within cause. My business address is 1001 - 

6th Street, Suite 500, Sacramento, California 95814. On this day I served the foregoing 

Document(s): STIPULATION AND REQUEST FOR REFERRAL TO THE COURT’S 

VOLUNTARY DISPUTE RESOLUTION PROGRAM 

X By Mail on the following party(ies) in said action in accordance with Code of Civil Procedure 

§1013(a), by placing a true copy thereof enclosed in a sealed envelope in a designated area for 

outgoing mail, addressed as set forth below. At Beeson, Tayer & Bodine, mail placed in that 

designated area is given the correct amount of postage and is deposited that same day, in the 

ordinary course of business in a United States mailbox in the City of Sacramento, California, 

addressed as follows: 

Wendy Moss, Esq. 

Ballard Rosenberg et al LLP 

10 Universal City Plaza 16FL 

Universal City, CA 91608-1097

 By Personal Delivering a true copy thereof, in accordance with Code of Civil Procedure 

§1011, to the person(s) and at the address(es) set forth below: 

 By Overnight Delivery on the following party(ies) in said action, in accordance with Code 

of Civil Procedure §1013(c), by placing a true and correct copy thereof enclosed in a sealed 

envelope, with delivery fees prepaid or provided for, in a designated outgoing overnight mail, 

addressed as set forth below. Mail placed in that designated area is picked up that same day, in 

the ordinary course of business for delivery the following day via United States Postal Service 

Express Mail. 

 By Facsimile Transmission, in accordance with Code of Civil Procedure §1013(e), to the 

following party(ies) at the facsimile numbers indicated below. 

Wendy Moss, Esq. 

Fax No. (818) 506-4827 

I declare under penalty of perjury that the foregoing is true and correct. Executed in 

Sacramento, California, on May 10, 2005. 

 /s/ Trisha Martin 

 Trisha Martin 

 BEESON, TAYER & BODINE 

Case 2:04-cv-01190-DFL-PAN Document 18 Filed 05/12/05 Page 3 of 3