Grotz v. Kaiser Foundation Hospitals et al

Filing 16

STIPULATION AND ORDER re #13 STIPULATION WITH PROPOSED ORDER FOR DISMISSAL AS TO THE PERMANENTE MEDICAL GROUP ONLY filed by Kaiser Foundation Hospitals, The Permanente Medical Group, Inc.. Signed by Judge Edward M. Chen on 8/29/12. (bpf, COURT STAFF) (Filed on 8/29/2012)

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1 George F. Camerlengo (SBN 50232) george@ccandjlaw.com 2 CAMERLENGO & JOHNSON 643 Bair Island Road, Ste. 400 3 Redwood City, CA 94063 Tel. (650) 366-2911 4 Fax (650) 365-7981 5 Attorney for Plaintiff 6 KRISTINNA GROTZ 7 8 9 10 11 12 Michele Ballard Miller (SBN 104198) mbm@millerlawgroup.com Katherine L. Kettler (SBN 231586) klk@millerlawgroup.com MILLER LAW GROUP A Professional Corporation 111 Sutter Street, Suite 700 San Francisco, CA 94104 Tel. (415) 464-4300 Fax (415) 464-4336 13 Attorneys for Defendant 14 KAISER FOUNDATION HOSPITALS 15 16 IN THE UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA 18 19 KRISTINNA GROTZ, an individual, 20 21 Plaintiff, Case No.: CV 12 3539 JSC STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL v. 22 23 KAISER FOUNDATION HOSPITALS, INC., THE PERMANENTE MEDICAL GROUP, 24 INC., SEIU-UNITED HEALTHCARE WORKERS WEST, 25 26 EMC Complaint filed: July 6, 2012 Defendants. 27 28 STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL Case No.: CV 12 3539 JSC 1 It is hereby stipulated by Plaintiff Kristinna Grotz (“Grotz”) and Defendant 2 Kaiser Foundation Hospitals (“KFH”), as follows: 3 4 1. Grotz will dismiss with prejudice TPMG as a named defendant in this 5 matter. Grotz and TPMG will bear their own fees and costs incurred in connection with this 6 dismissal. 7 8 2. KFH stipulates it was Grotz’s employer during all relevant times 9 alleged in the Complaint in this matter, and that TPMG was not Grotz’s employer during 10 any relevant times alleged in the complaint in this matter. During the pendency of this 11 action, neither Grotz nor KFH will assert otherwise. 12 13 IT IS SO STIPULATED. 14 15 Dated: August 24, 2012 CAMERLENGO & JOHNSON 16 By: 17 18 /S/ George F. Camerlengo Attorney for Plaintiff Kristinna Grotz 19 20 Dated: August 24, 2012 MILLER LAW GROUP A Professional Corporation 21 22 23 24 By: /S/ Michele B. Miller Attorneys for Defendant Kaiser Foundation Hospitals 25 26 27 28 1 STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL Case No.: CV 12 3539 JSC 1 ORDER 2 3 As stipulated and agreed to by Plaintiff Kristinna Grotz and Defendant Kaiser 4 Foundation Hospitals, defendant The Permanente Medical Group, Inc. is hereby dismissed 5 from this action with prejudice. 6 dward Judge E RT 12 AS MO ER 14 n M. Che A H 13 R NIA DIFIE FO 11 4815-6485-6336, v. 1 _______________________________________ DERED HONORABLE EDWARDR CHEN SO O M. D IT IS LI 10 8/29 Dated: ______________, 2012 UNIT ED 9 NO 8 S DISTRICT TE C TA RT U O S 7 IT IS SO ORDERED. N F D IS T IC T O R 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL Case No.: CV 12 3539 JSC C

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