Prime Healthcare Services - Shasta, LLC v. Burwell

Filing 16

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 7/25/2017 ORDERING that plaintiff shall file first amended complaints on or before 8/14/2017. Defendant's responses to the first amended complaints shall be filed on or before 9/5/2017. (Donati, J)

1 Troy A. Schell, Esq. (SBN 208661)
Bryan Wong, Esq. (SBN 205573)
2 3300 East Guasti Road, 3rd Floor
Ontario, California 91761
3 Telephone:
[phone]
Facsimile:
[phone]
4
Attorneys for Plaintiff
5 Prime Healthcare Services – Shasta, LLC,
d.b.a Shasta Regional Medical Center
6
7 PHILLIP A. TALBERT
United States Attorney
8 PHILIP A. SCARBOROUGH
JOSEPH B. FRUEH
9 Assistant United States Attorneys
501 I Street, Suite 10-100
10 Sacramento, CA 95814
E-mail:
[e-mail]
11
[e-mail]
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for Defendant
THOMAS E. PRICE, M.D.
14 Secretary, Department of Health & Human Services
15
16

IN THE UNITED STATES DISTRICT COURT

17

EASTERN DISTRICT OF CALIFORNIA

18
19 PRIME HEALTHCARE SERVICES –
SHASTA LLC, a Delaware limited liability
20 company doing business as Shasta Regional
Medical Center,
21
Plaintiff,
22
v.
23
THOMAS E. PRICE, M.D., in his official
24 capacity as Secretary of the Department of
Health and Human Services,
25
Defendant.
26
27
28

Case Nos. 2:17-cv-00069-TLN-KJN
2:17-cv-00071-TLN-KJN
2:17-cv-00072-TLN-KJN
2:17-cv-00073-TLN-KJN
2:17-cv-00074-TLN-KJN
2:17-cv-00082-TLN-KJN
2:17-cv-00431-TLN-KJN
STIPULATION AND ORDER FOR:
(1) AMENDING THE COMPLAINT; AND
(2) SETTING DEFENDANT’S DEADLINE
FOR RESPONDING TO THE AMENDED
COMPLAINT

1
2

STIPULATION AND PROPOSED ORDER
IT IS HEREBY STIPULATED, by and between Plaintiff Prime Healthcare Services – Shasta,

3 LLC, and Defendant Thomas E. Price, M.D., through their undersigned counsel and subject to Court
4 approval, that:
5

1.

Plaintiff shall file First Amended Complaints in each of the above-captioned related cases

6 on or before August 14, 2017; and
7

2.

Defendant’s responses to the First Amended Complaints in the above-captioned related

8 cases shall be filed on or before September 5, 2017.
9

Having met and conferred, the parties arrived at this Stipulation and Proposed Order to allow

10 Plaintiff to supplement its factual allegations in the operative pleadings and potentially avoid
11 unnecessary motions to dismiss under Rules 12(b)(6) and 8(a) of the Federal Rules of Civil Procedure.
12 Dated: July 24, 2017

PHILLIP A. TALBERT
United States Attorney

13
By:

14
15
16

/s/ Joseph B. Frueh
JOSEPH B. FRUEH
PHILIP A. SCARBOROUGH
Assistant United States Attorneys
Attorneys for Defendant
THOMAS E. PRICE, M.D.
Secretary, Department of Health & Human Services

17

TROY A. SCHELL, ESQ.
BRYAN WONG, ESQ.

18
19
20

By:

21

/s/ Bryan Wong
Bryan Wong, Esq.

(authorized on 7/24/2017)

Attorneys for Plaintiff
Prime Healthcare Services – Shasta, LLC

22
23
24 IT IS SO ORDERED.
25 Dated: July 25, 2017
26

Troy L. Nunley
United States District Judge

27
28
STIP. & PROPOSED ORDER TO (1) AMEND COMPL.; AND
(2) SET DEADLINE FOR RESP. TO AMEND. COMPL.

1