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2001399.1 

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

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MERY STREET, SUITE 10

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SAN FRANCISC

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ALIFORNIA 94104

TEL: (415) 875-850

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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 GGH 

JOINT STIPULATION FOR 

ADDITIONAL STAY OF DISCOVERY 

AND EXTENSION OF TRIAL AND PRETRIAL DATES 

Date: May 8, 2006 

Time: 9:00 a.m. 

Judge: Honorable David F. Levi 

Complaint Filed: June 10, 2004 

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), July 7, 2005 (July Stipulation) and 

Case 2:04-cv-01124-DFL-PAN Document 29 Filed 09/13/05 Page 1 of 4
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2001399.1 2 

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

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ALIFORNIA 94104

TEL: (415) 875-850

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August 11, 2005 (August Stipulation) jointly requested a stay of the entire 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 August Stipulation entered by the 

Court on August 15, 2005, be extended subject to the Court’s approval, to the following dates or 

other dates convenient to the Court: 

Initial Expert Witness 

Disclosures 

September 9, 2005 October 7, 2005 

Defendant’s responses to 

Plaintiffs’ First Set of 

Request for Production, 

Requests for Admissions, 

and Interrogatories 

September 14, 2005 October 21, 2005 

Plaintiffs’ responses to 

Defendant’s First Set of 

Request for Production and 

Interrogatories 

September 14, 2005 October 21, 2005 

Case 2:04-cv-01124-DFL-PAN Document 29 Filed 09/13/05 Page 2 of 4
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2001399.1 3 

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

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ALIFORNIA 94104

TEL: (415) 875-850

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Supplemental Expert 

Witness Disclosures 

September 23, 2005 October 21, 2005 

Close of Discovery November 18, 2005 December 16, 2005 

Deadline for Filing of 

Dispositive Motions 

January 18, 2006 February 15, 2006 

Hearing on Dispositive 

Motions 

February 15, 2006 at 10:00 a.m. March 15, 2006 at 10:00 a.m. 

Pre-Trial Conference 

Statement 

March 24, 2006 April 21, 2006 

Pre-Trial Conference March 24, 2006 at 3:00 p.m. April 28, 2006 at 2:00 p.m. 

Trial May 8, 2006 at 9:00 a.m. June 12, 2006 at 9:00 a.m. 

DATED: September 9, 2005 HOOPER, LUNDY & BOOKMAN, INC. 

By: /s/ 

FELICIA Y SZE 

Attorneys for Plaintiffs 

DATED: September 9, 2005 SANDRA SHEWRY, Director of the Department of 

Health Services 

By: /s/ 

JULIE WENG-GUTIERREZ 

Attorneys for Defendant 

Case 2:04-cv-01124-DFL-PAN Document 29 Filed 09/13/05 Page 3 of 4
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2001399.1 4 

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

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ALIFORNIA 94104

TEL: (415) 875-850

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[PROPOSED] ORDER 

For good cause shown, 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 October 7, 2005 

Supplemental Expert Witness Disclosures October 21, 2005 

Close of Discovery December 16, 2005 

Deadline for Filing Dispositive Motions February 15, 2006 

Hearing on Dispositive Motions March 15, 2006 at 10:00 a.m. 

Pre-Trial Conference Statement April 21, 2006 

Pre-Trial Conference April 28, 2006, at 2:00 p.m. 

Trial June 12, 2006 at 9:00 a.m. 

DATED: September_9, 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 29 Filed 09/13/05 Page 4 of 4