Filed: Apr. 29, 2016
Latest Update: Apr. 29, 2016
Summary: STIPULATED REQUEST TO TAKE TWO THIRD-PARTY DEPOSITIONS POST FACT DISCOVERY CUTOFF; ORDER TROY L. NUNLEY , District Judge . Plaintiffs United States of America and the State of California, ex rel., Douglas Dalitz and Randy Gray ("Relators") and Defendants AmSurg Corp., Gastroenterology Associates Endoscopy Center, L.L.C., Redding Gastroenterology, L.L.C., d/b/a Redding Endoscopy Center, Gaddam Naresh Reddy, M.D., Piyush Kumar Dhanuka, M.D., and B. Nicholas Namihas, M.D. through their attorne
Summary: STIPULATED REQUEST TO TAKE TWO THIRD-PARTY DEPOSITIONS POST FACT DISCOVERY CUTOFF; ORDER TROY L. NUNLEY , District Judge . Plaintiffs United States of America and the State of California, ex rel., Douglas Dalitz and Randy Gray ("Relators") and Defendants AmSurg Corp., Gastroenterology Associates Endoscopy Center, L.L.C., Redding Gastroenterology, L.L.C., d/b/a Redding Endoscopy Center, Gaddam Naresh Reddy, M.D., Piyush Kumar Dhanuka, M.D., and B. Nicholas Namihas, M.D. through their attorney..
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STIPULATED REQUEST TO TAKE TWO THIRD-PARTY DEPOSITIONS POST FACT DISCOVERY CUTOFF; ORDER
TROY L. NUNLEY, District Judge.
Plaintiffs United States of America and the State of California, ex rel., Douglas Dalitz and Randy Gray ("Relators") and Defendants AmSurg Corp., Gastroenterology Associates Endoscopy Center, L.L.C., Redding Gastroenterology, L.L.C., d/b/a Redding Endoscopy Center, Gaddam Naresh Reddy, M.D., Piyush Kumar Dhanuka, M.D., and B. Nicholas Namihas, M.D. through their attorneys, hereby stipulate and request modification of this Court's Pretrial Scheduling Order (the "Scheduling Order"), filed January 19, 2016 (Dkt. 77).
The Pretrial Scheduling Status Order establishes April 29, 2016 as the date that discovery is to be completed. The parties request permission to take two third-party depositions after the fact discovery cutoff of April 29, 2016.
The parties submit that there is good cause for this request. The parties jointly represent to the Court that this requested continuance is not a result of dilatory tactics or lack of diligence by the parties. The parties have diligently pursued the completion of fact discovery. All noticed depositions (including party depositions) have been completed with the exception of two third-party depositions. The deposition of Somnia, Inc. is scheduled to take place in New York on May 11, 2016 and the deposition of former Amsurg employee Lori Wenham is scheduled to take place in Colorado on May 13, 2016. It has been necessary to schedule these depositions to take place after the discovery cutoff due to the availability of these third-party witnesses and counsel for relators who is scheduled to be out of the country the weeks of April 25 and May 2. The parties seek additional time to complete these two depositions only. The taking of these two depositions after the discovery cutoff will not affect the parties' ability to comply with all other dates in the court's pretrial scheduling order, including the completion of expert discovery.
IT IS SO STIPULATED.
IT IS SO ORDERED.
