Filed: Aug. 18, 2015
Latest Update: Aug. 18, 2015
Summary: STIPULATION AND PROPOSED ORDER TO EXTEND THE DEADLINE TO FILE A RESPONSIVE PLEADING [L.R. 144(a)] TROY L. NUNLEY , District Judge . Plaintiff Prime Healthcare Services — Shasta, LLC, and Defendant Sylvia Burwell, Secretary of the Department of Health and Human Services, by and through their attorneys, hereby stipulate, subject to approval of the Court, to extend the deadline for filing a responsive pleading to Plaintiff's First Amended Complaint from September 4, 2015, to October 5, 2015, i
Summary: STIPULATION AND PROPOSED ORDER TO EXTEND THE DEADLINE TO FILE A RESPONSIVE PLEADING [L.R. 144(a)] TROY L. NUNLEY , District Judge . Plaintiff Prime Healthcare Services — Shasta, LLC, and Defendant Sylvia Burwell, Secretary of the Department of Health and Human Services, by and through their attorneys, hereby stipulate, subject to approval of the Court, to extend the deadline for filing a responsive pleading to Plaintiff's First Amended Complaint from September 4, 2015, to October 5, 2015, in..
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STIPULATION AND PROPOSED ORDER TO EXTEND THE DEADLINE TO FILE A RESPONSIVE PLEADING [L.R. 144(a)]
TROY L. NUNLEY, District Judge.
Plaintiff Prime Healthcare Services — Shasta, LLC, and Defendant Sylvia Burwell, Secretary of the Department of Health and Human Services, by and through their attorneys, hereby stipulate, subject to approval of the Court, to extend the deadline for filing a responsive pleading to Plaintiff's First Amended Complaint from September 4, 2015, to October 5, 2015, in light of the following:
Plaintiff has filed a total of 9 cases challenging determinations by the Medicare Appeals Council that Plaintiff lacked standing to appeal the denial of its claims for payment for emergency medical services provided to multiple Medicare beneficiaries between November 2008 and February 2009. The parties have previously stipulated to a responsive deadline of September 4, 2015, in each of these 9 cases.
In light of defendant's attorney's workload — which includes a trial in September in Koval v. United States, 2:13-cv-2552-JAM-DAD, depositions currently scheduled for September in E.R. v. Sutter Davis Hospital, 2:14-cv-2053-WBS-CKD, a reply brief due in September in Bullen v. Lynch, 2:13-cv-1349-TMB (Dist. of Ariz.), a reply brief due in September in Muir v. United States, 2:14-cv-2716-MCE-CKD, and a 9th Circuit oral argument in October in Grinols v. Electoral College, Ninth Circuit Appeal No. 13-16359, the parties hereby stipulate, subject to approval of the Court, to extend the deadline for a responsive pleading in the above-captioned matter from September 4, 2015, to October 5, 2015.
Although the parties have not previously asked for an extension of time to file a responsive pleading to the First Amended Complaint, the parties have previously filed several stipulations for extensions of time to file a responsive pleading to the original Complaint (totaling over 90 days in most of the nine cases). The parties appreciate the Court's patience in this matter.
ORDER
Pursuant to stipulation and good cause having been shown, IT IS SO ORDERED that the responsive pleading deadline is moved to October 5, 2015.
