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govinfo:USCOURTS-caed-2_25-cv-00959-4
1 STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANTS CALIFORNIA FORENSIC MEDICAL GROUP AND DIANA McGINNIS TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS’ SECOND AMENDED COMPLAINT 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 Paul A. Cardinale, State Bar No. 215812 Subreen K. Sandhu, State Bar No. 348040 MEDICAL DEFENSE LAW GROUP 3800 Watt Avenue, Suite 245 Sacramento, CA 95821 Tel: (916) 244-9116 Fax: (916) 244-9130 paul.cardinale@med-defenselaw.com subreen.sandhu@med-defenselaw.com Attorneys for Defendants CALIFORNIA FORENSIC MEDICAL GROUP, INC. and DIANA MCGINNIS UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA CHRISTOPHER BRIAN OREGLIA AND DIANA COOK, Plaintiffs, vs. COUNTY OF PLACER; PLACER COUNTY BOARD OF SUPERVISORS; PLACER COUNTY DEPUTY SHERIFF ANDREW SANCHEZ (BADGE 131); BRANDON HANN (BADGE NO. 1410); SHERIFF WAYNE WOO; DEPUTY SHERIFF EVAN MILLER; DEPUTY SHERIFF SOLVERSON; CALIFORNIA FORENSIC MEDICAL GROUP, INC. (WELLPATH); CALIFORNIA FORENSIC MEDICAL GROUP (CFG); DIANA McGINNIS; and Does 1-40, inclusive, Defendants. STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANTS CALIFORNIA FORENSIC MEDICAL GROUP AND DIANA McGINNIS TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS’ SECOND AMENDED COMPLAINT (ECF No. 40) Complaint Filed: March 27, 2025 1 st Am. Comp Filed: September 2, 2025 2nd Am. Comp Filed: May 18, 2026 Trial Date: None Set Plaintiffs, CHRISTOPHER BRIAN OREGLIA and DIANA COOK, through their attorney, Kevin W. Harris, and Defendants, CALIFORNIA FORENSIC MEDICAL GROUP, INC. and DIANA McGINNIS, through their attorneys, Paul A. Cardinale and Subreen K. Sandhu of Medical Defense Law Group, hereby submit their Stipulation and Proposed Order extending the deadline for Defendants 2 STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANTS CALIFORNIA FORENSIC MEDICAL GROUP AND DIANA McGINNIS TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS’ SECOND AMENDED COMPLAINT 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 CALIFORNIA FORENSIC MEDICAL GROUP, INC. and DIANA MCGINNIS to file a responsive pleading to Plaintiffs’ Second Amended Complaint in this matter, for the reasons set forth below. BACKGROUND On March 27, 2025, Plaintiffs filed their Complaint. (ECF 1.) On September 2, 2025, Plaintiffs filed their First Amended Complaint. (ECF 6.) On November 24, 2025, the Summons was served upon Defendant DIANA McGINNIS. On November 25, 2025, the Summons was served upon Defendant CALIFORNIA FORENSIC MEDICAL GROUP. On December 16, 2025, Defendants CALIFORNIA FORENSIC MEDICAL GROUP, INC. and DIANA McGINNIS filed a Motion to Dismiss before Chief Magistrate Judge Carolyn K. Delaney with a hearing date of January 21, 2026. (ECF 20.) On December 17, 2025, the Court entered an order vacating the Motion to Dismiss hearing date of January 21, 2026, without prejudice, with an instruction to re-notice the motion before newly assigned Senior Judge John A. Mendez. (ECF 21.) On January 15, 2026, Defendants CALIFORNIA FORENSIC MEDICAL GROUP, INC. , and DIANA McGINNIS filed an Amended Motion to Dismiss before Senior Judge John A. Mendez with a hearing date of April 21, 2026. (ECF 25.) On March 23, 2026, Plaintiffs filed their Opposition to Defendants’ Motion to Dismiss. (ECF 28.) On March 27, 2026, the Court, on its own motion, moved the hearing for Defendants CALIFORNIA FORENSIC MEDICAL GROUP, INC. and DIANA M cGINNIS’ Motion to Dismiss to April 28, 2026. (ECF 30.) On April 14, 2026, Defendants CALIFORNIA FORENSIC MEDICAL GROUP, INC. and DIANA McGINNIS filed their Reply to Plaintiffs’ Opposition to the Motion to Dismiss. (ECF 34.) On April 28, 2026, the Court heard the Motion to Dismiss and granted it, dismissing Plaintiff Diana Cook without prejudice and granting leave to amend within 20 days. Defendants were ordered to file their responsive pleading within 20 days thereafter, on or before June 8, 2026. (ECF 36.) On May 18, 2026, Plaintiffs filed their Second Amended Complaint. (ECF 37.) In an email exchange on June 4, 2026, Subreen K. Sandhu, counsel for Defendants CALIFORNIA FORENSIC MEDICAL GROUP, INC. , and DIANA M cGINNIS, and Kevin W. Harris, counsel for 3 STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANTS CALIFORNIA FORENSIC MEDICAL GROUP AND DIANA McGINNIS TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS’ SECOND AMENDED COMPLAINT 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 Plaintiffs, agreed that it would be prudent to meet and confer telephonically to attempt to resolve some or all of the deficiencies in the Second Amended Complaint, potentially streamlining or eliminating the need for a motion to dismiss. Accordingly, on June 4, 2026, counsel for both parties stipulated to extend the deadline to file the responsive pleading to Plaintiffs’ Second Amended Complaint to June 22, 2026. STIPULATION ACCORDINGLY, counsel for the parties hereby stipulate that Defendant s CALIFORNIA FORENSIC MEDICAL GROUP, INC. and DIANA McGINNIS shall have until June 22, 2026 to file a responsive pleading to Plaintiffs’ Second Amended Complaint. Dated: June 4, 2026 MEDICAL DEFENSE LAW GROUP /s/ Subreen K. Sandhu Paul A. Cardinale Subreen K. Sandhu Attorneys for Defendants CALIFORNIA FORENSIC MEDICAL GROUP, INC. and DIANA MCGINNIS Dated: June 4, 2026 LAW OFFICES OF KEVIN W. HARRIS /s/ Kevin W. Harris Kevin W. Harris Attorney for Plaintiffs CHRISTOPHER BRIAN OREGLIA and DIANA COOK 4 STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANTS CALIFORNIA FORENSIC MEDICAL GROUP AND DIANA McGINNIS TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS’ SECOND AMENDED COMPLAINT 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 ORDER IT IS SO ORDERED that Defendant s CALIFORNIA FORENSIC MEDICAL GROUP, INC. and DIANA McGINNIS shall have until June 22 , 2026, to file a responsive pleading to Plaintiffs’ Second Amended Complaint. Dated: June 05, 2026