Cummings v. United Healthcare Services, Inc. et al

Filing 50

ORDER re 49 Status Report. The rebuttal expert deadline is extended to 5/9/2014 with all other discovery deadlines to remain the same pursuant to the Court's 40 Order. Discovery will close 5/19/2014. Defendant agrees that Plaintiff will have until 6/8/2014 to depose Defendant's rebuttal expert, if one is retained in this matter. Signed by Magistrate Judge George Foley, Jr on 4/21/2014. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:13-cv-00479-APG-GWF Document 49 Filed 04/14/14 Page 1 of 2

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WENDY MEDURA KRINCEK, ESQ., Bar # 6417
JAMIE CHU, ESQ., Bar # 10546
LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway, Suite 300
Las Vegas, NV 89169-5937
Telephone:
702.862.8800
Fax No.:
702.862.8811
Attorneys for Defendants
VALLEY HEALTH SYSTEM, LLC, D/B/A DESERT SPRINGS
HOSPITAL; AND RAEJOHNE FOSTER

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ANGELA CUMMINGS,

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Plaintiff,

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vs.

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VALLEY HEALTH SYSTEM, LLC, a
Delaware Limited-Liability Company d/b/a
DESERT SPRINGS HOSPITAL;
RAEJOHNE FOSTER, an individual,

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LITTLE R MEND ELSO N, P .C .
ATTORNEYS AT LAW
3960 H oward Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800

STATUS REPORT PURSUANT TO
ORDER (DOC. 46) AND ORDER TO
EXTEND THE REBUTTAL EXPERT
DEADLINE

Defendants.

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CASE NO. 2:13-CV-00479-APG-GWF

Plaintiff Angela Cummings (“Plaintiff”), and Defendants Valley Health System, LLC, d/b/a
Desert Springs Hospital and RaeJohne Foster (hereinafter collectively referred to as “Defendants”),
by and through their undersigned counsel, hereby file this Status Report to the Court pursuant to its
Order (Doc. 46) regarding the Stipulation and Order to Extend the Rebuttal Expert Deadline (Doc.
45).
As the Court is aware, Defendants served the subpoena for Plaintiff’s medical records to
Southwest Medical Associates on March 17, 2014. Southwest Medical Associates’ response to the
subpoena for records was due on or before April 4, 2014. Defendants received Southwest Medical
Associates’ subpoena response on April 9, 2014, which consists of 826 pages.
The Order provides that upon receipt of a status report regarding the receipt of the medical

Case 2:13-cv-00479-APG-GWF Document 49 Filed 04/14/14 Page 2 of 2

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records the Court would grant a 30 day extension of the deadline to make rebuttal expert disclosures

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(Doc. 46). Accordingly, the parties respectfully request that the Court grant their Stipulation and

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Order to amend the current scheduling order and discovery plan (third request) by extending the

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current rebuttal expert deadline date of March 24, 2014 for 30 days from April 9, 2014, the date

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Defendants received the subpoena response from Southwest Medical Associates, to May 9, 2014,

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with all other discovery deadlines to remain the same pursuant to the Court’s Order (Doc. 40) filed

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on January 14, 2014. As such, discovery in this matter will close on May 19, 2014 (Doc. 40).

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However, notwithstanding the discovery date, Defendant agrees that Plaintiff will have until June 8,

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2014 to depose Defendant’s rebuttal expert, if one is retained in this matter. This extension is sought

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in good faith and not for the purpose of delay.
Dated: April 14, 2014

Dated: April 14, 2014

Respectfully submitted,

Respectfully submitted,

/s/ James P. Kemp, Esq.
JAMES P. KEMP, ESQ.
KEMP & KEMP, ATTORNEYS AT LAW

/s/ Jamie Chu, Esq.
WENDY MEDURA KRINCEK, ESQ.
JAMIE CHU, ESQ.
LITTLER MENDELSON, P.C.

Attorneys for Plaintiff

Attorneys for Defendants

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ORDER

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IT IS SO ORDERED.

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21st
Dated this ______ day of April, 2014

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___________________________________________
UNITED STATES MAGISTRATE JUDGE

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LITTLE R MEND ELSO N, P .C .
ATTORNEYS AT LAW
3960 H oward Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800

Firmwide:126260355.1 069080.1036

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