Ochoa v. Costco Wholesale Corp.

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STIPULATION RE: PHYSICAL EXAMINATION OF PLAINTIFF GRICELDA OCHOA

SETTE LAW, PC

Frederick J. Sette (SBN: 173569)

472 W. Putnam Avenue

333 University Ave, Suite 200 Sacramento, CA 95825

T: 916-442-0000

F: 916-442-0001

fred@settelaw.com

info@settelaw.com

Attorneys for Plaintiff, GRICELDA OCHOA Law Offices of

MATHENY SEARS LINKERT & JAIME LLP

MATTHEW C. JAIME (SBN 140340)

S.J. K. HAMMON (SBN 364464)

3638 American River Drive Sacramento, California 95864 Telephone: (916) 978-3434 Facsimile: (916) 978-3430 mjaime@mathenysears.com shammon@mathenysears.com Attorneys for Defendant, COSTCO WHOLESALE

CORPORATION

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

GRICELDA OCHOA

Plaintiff, v.

COSTCO WHOLESALE

CORPORATION and DOES 1 to 25, inclusive,

Defendants.

Case No. 2:26-cv-01121-TLN-CSK

STIPULATION AND ORDER RE:

PHYSICAL EXAMINATION OF

PLAINTIFF GRICELDA OCHOA

Complaint filed: 07/30/2025 Trial date: Unassigned Plaintiff GRICELDA OCHOA ("Plaintiff") and Defendant COSTCO WHOLESALE CORPORATION ("Defendant") agree and stipulate that Plaintiff shall submit to a physical examination pursuant to Federal Rules of Civil Procedure, Rule 35:

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1. A controversy exists regarding the physical condition of Plaintiff and good cause exists for a physical examination of Plaintiff.

2. The examination will be conducted for the purpose of determining the nature and extent of Plaintiff's physical injuries.

3. The scope of the examination will be the physical injuries at issue in litigation. Specifically, the injuries that are alleged and at issue are to Plaintiff's left shoulder, left knee, and low back.

4. The physical examination will be conducted by Dr. Patrick McGahan, M.D. — the independent medical exam physician retained by Defendant. Attached to this stipulation as Exhibit A is a true and correct copy of Dr. McGahan's Curriculum Vitae setting forth his qualifications and background.

5. The date and time for the physical examination will be September 30, 2026, 3:00 p.m.

6. The location for the examination is: 3941 J St, Ste 250, Sacramento, CA 95819.

7. Dr. McGahan's contact information is(916) 995-5683.

8. It is further stipulated that Defendant will be responsible for the fees associated with this examination.

9. However, Plaintiff agrees to reasonably comply with Dr. McGahan's cancellation policy and must advise Defendant if she is unable to attend the examination at least five business days before the examination.

Dated: ____________ SETTE LAW, PC

By:

Frederick J. Sette, ESQ. Attorney for Plaintiff GRICELDA OCHOA

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7/28/26

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