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2000690.1 

JOINT STIPULATION FOR ADDITIONAL STAY OF DISCOVERY AND EXTENSION OF TRIAL AND PRETRIAL DATES

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MARK E. REAGAN (State Bar No. 143438) 

CRAIG J. CANNIZZO (State Bar No. 70379) 

FELICIA Y. SZE (State Bar No. 233441) 

HOOPER, LUNDY & BOOKMAN, INC. 

180 Montgomery Street, Suite 1000 

San Francisco, California 94104 

Telephone: (415) 875-8500 

Facsimile: (415) 875-8519 

E-Mail: fsze@health-law.com OK/HAV 

Attorneys for CALIFORNIA ASSOCIATION 

OF MEDICAL PRODUCT SUPPLIERS, 

MICHAEL ELLENWOOD and MICHAEL 

JOHNSON 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA, 

SACRAMENTO DIVISION 

CALIFORNIA ASSOCIATION OF 

MEDICAL PRODUCT SUPPLIERS; 

MICHAEL ELLENWOOD; and MICHAEL 

JOHNSON, 

Plaintiffs, 

vs. 

SANDRA SHEWRY, DIRECTOR OF THE 

DEPARTMENT OF HEALTH SERVICES, 

STATE OF CALIFORNIA, 

Defendants. 

CASE NO. CIV.S-04-1124 DFL PAN 

JOINT STIPULATION FOR 

ADDITIONAL STAY OF DISCOVERY 

AND EXTENSION OF TRIAL AND PRETRIAL DATES 

Plaintiffs California Association of Medical Product Suppliers, Michael Ellenwood, and 

Michael Johnson (Plaintiffs) and Defendant Sandra Shewry (Defendant) by and through their 

respective attorneys of record, hereby stipulate as follows: 

WHEREAS, Plaintiffs filed a complaint on June 10, 2004, against Defendant; 

WHEREAS, the parties have been engaged in good faith settlement discussions and thus 

on or about January 13, 2005, (January Stipulation), March 3, 2005, (March Stipulation), April 25, 

2005 (April Stipulation) and May 25, 2005 (May stipulation), jointly requested a stay of the entire 

Case 2:04-cv-01124-DFL-PAN Document 25 Filed 07/11/05 Page 1 of 4
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action, including the extension of all litigation deadlines and trial date to allow the parties to focus 

their time and energy on discussing settlement; 

WHEREAS, the Court signed both Stipulations granting a stay and extension dates for 

discovery, dispositive motions, pre-trial conference and trial date; 

WHEREAS, the parties are currently engaged in ongoing good faith settlement 

discussions; 

WHEREAS, all parties mutually agree that settlement discussions will continue to be 

helpful in resolving most, if not all, of the material disputes of this case and that additional time is 

necessary in order to facilitate settlement; 

WHEREAS, good cause exists to grant a further stay and extension of the litigation 

deadlines and trial date based on the parties’ good faith belief that they may resolve their disputes 

without the need for further Court intervention, thereby eliminating the need for use of the Court’s 

limited resources; 

IT IS HEREBY STIPULATED THAT: 

1. The action is stayed in its entirety for an additional 30 days upon the signing of the 

Order. 

2. The trial date, and all other dates set forth in the May Stipulation entered by the 

Court on May 26, 2005, be extended subject to the Court’s approval, to the following dates or 

other dates convenient to the Court: 

Initial Expert Witness 

Disclosures 

July 11, 2005 August 12, 2005 

Defendant’s responses to 

Plaintiffs’ First Set of Request 

for Production, Requests for 

Admissions, and 

Interrogatories 

July 15, 2005 August 15, 2005 

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2000690.1 3 

JOINT STIPULATION FOR ADDITIONAL STAY OF DISCOVERY AND EXTENSION OF TRIAL AND PRETRIAL DATES

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Plaintiffs’ responses to 

Defendant’s First Set of 

Request for Production and 

Interrogatories 

July 15, 2005 August 15, 2005 

Supplemental Expert Witness 

Disclosures 

July 25, 2005 August 26, 2005 

Close of Discovery September 15, 2005 October 14, 2005 

Deadline for Filing of 

Dispositive Motions 

November 9, 2005 December 21, 2005 

Hearing on Dispositive 

Motions 

December 7, 2005 January 18, 2006 at 10:00 a.m. 

Pre-Trial Conference January 27, 2006 March 3, 2006 at 3:00 p.m. 

Trial March 6, 2006 April 10, 2006 

DATED: July 7, 2005 HOOPER, LUNDY & BOOKMAN, INC. 

By: /s/ 

FELICIA Y SZE 

Attorneys for Plaintiffs 

DATED: July 7, 2005 SANDRA SHEWRY, Director of the Department of 

Health Services 

By: /s/ 

JULIE WENG-GUTIERREZ 

Attorneys for Defendant 

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2000690.1 4 

JOINT STIPULATION FOR ADDITIONAL STAY OF DISCOVERY AND EXTENSION OF TRIAL AND PRETRIAL DATES

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TEL: (415) 875-850

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[PROPOSED] ORDER 

For good cause show, the Court hereby postpones the scheduled dates for discovery, filing 

of dispositive motions, hearing on dispositive motions, final pre-trial conference and trial as 

follows: 

Initial Expert Witness Disclosures August 12, 2005 

Supplemental Expert Witness Disclosures August 26, 2005 

Close of Discovery October 14, 2005 

Deadline for Filing Dispositive Motions December 21, 2005 

Hearing on Dispositive Motions January 18, 2006 at 10:00 a.m. 

Pre-Trial Conference March 3, 2006 at 3:00 p.m. 

Trial April 10, 2006 at 8:30 a.m. 

DATED: July 7, 2005 

By: /s/ David F. Levi 

 The Honorable David F. Levi 

Judge of the United States District Court 

Case 2:04-cv-01124-DFL-PAN Document 25 Filed 07/11/05 Page 4 of 4