Prime Healthcare Services - Shasta, LLC v. Burwell

Filing 8

STIPULATION and ORDER TO CONTINUE DEFENDANT'S RESPONSE TO THE COMPLAINT signed by District Judge Morrison C. England, Jr on 5/31/17. The deadline for Defendant's response to the Complaint be continued until after the Court issues a decision on Defendant's Motion for Stay of Proceedings (ECF No. 6), which is scheduled to be heard on 6/29/17.(Mena-Sanchez, L)

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
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16

IN THE UNITED STATES DISTRICT COURT

17

EASTERN DISTRICT OF CALIFORNIA

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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.
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28

Case No. 2:17-CV-00431-MCE-CMK
STIPULATION AND ORDER TO CONTINUE
DEFENDANT’S RESPONSE TO THE
COMPLAINT

1

IT IS HEREBY STIPULATED, by and between Plaintiff Prime Healthcare Services – Shasta,

2 LLC, and Defendant Thomas E. Price, M.D., through their undersigned counsel and subject to Court
3 approval, that the deadline for Defendant’s response to the Complaint be continued until after the Court
4 issues a decision on Defendant’s Motion for Stay of Proceedings (ECF No. 6), which is scheduled to be
5 heard on June 29, 2017. Defendant’s response to the Complaint is currently due on May 30, 2017.
6

Specifically, the parties stipulate that, subject to Court approval, Defendant shall file his response

7 to the Complaint within 30 days of the date of an order denying Defendant’s Motion, or within 30 days
8 of the date of an order lifting the requested stay of proceedings, whichever is applicable. The Court
9 approved this same stipulation in related actions numbered 2:17-cv-00069-TLN-KJN (ECF No. 11);
10 2:17-cv-00071-TLN-KJN (ECF No. 12); 2:17-cv-00072-TLN-KJN (ECF No. 9); 2:17-cv-00073-TLN11 KJN (ECF No. 10); 2:17-cv-00074-TLN-KJN (ECF No. 10); and 2:17-cv-00082-TLN-KJN (ECF
12 No. 10). A Notice of Related Case was filed in the instant proceeding on May 21, 2017. ECF No. 5.
13 Dated: May 30, 2017

PHILLIP A. TALBERT
United States Attorney

14
By:

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16
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Attorneys for Defendant
THOMAS E. PRICE, M.D.
Secretary, Department of Health & Human Services

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19

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

20
21

By:

22

25

/s/ Bryan Wong
Bryan Wong, Esq.

(authorized on 5/30/2017)

Attorneys for Plaintiff
Prime Healthcare Services – Shasta, LLC

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24

/s/ Joseph. B. Frueh
JOSEPH B. FRUEH
PHILIP A. SCARBOROUGH
Assistant United States Attorneys

IT IS SO ORDERED.
Dated: May 31, 2017

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STIPULATION TO CONTINUE DEFENDANT’S RESPONSE
TO THE COMPLAINT

1