My Health, Inc. v. Intermountain Health Care, Inc.

Filing 29

ORDER Granting 28 Stipulation for Fourth Extension of Time to Respond to 1 Complaint, filed by My Health, Inc. Defendant, Intermountain Health Care, Inc. answer is now due 7/13/2015. Signed by Judge Miranda M. Du on 6/22/2015. (Copies have been distributed pursuant to the NEF - PS)

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STOEL RIVES LLP

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Michael B. Brown, Nevada Bar No. 6577
[e-mail]
10008 SE River Street
Truckee, CA 96161
Tel: [phone]
Fax: [phone]

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Joshua G. Gigger (Pro Hac Vice)
[e-mail]
Marc T. Rasich (Pro Hac Vice)
[e-mail]
201 South Main Street, Suite 1100
Salt Lake City, UT 84111
Tel: [phone]
Fax: [phone]
Hunter O. Ferguson (Pro Hac Vice)
[e-mail]
600 University Street, Suite 3600
Seattle, WA 98101
Tel: [phone]
Fax: [phone]

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Counsel for Defendant
Intermountain Health Care, Inc.

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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MY HEALTH, INC., a Delaware corporation,

Case No. 2:15-cv-00073-MMD-CWH

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Plaintiff,

STIPULATION FOR FOURTH
EXTENSION OF TIME TO RESPOND

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v.
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INTERMOUNTAIN HEALTH CARE, INC., a
Utah corporation,

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Defendant.

(Fourth Request for Extension of this
Deadline; Fourth Overall Extension
Request)
Current Response Deadline:
June 29, 2015

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Plaintiff My Health, Inc. (“My Health”) and Defendant Intermountain Health Care, Inc.

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(“Intermountain”) have stipulated to, and respectfully request that the Court enter an order

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providing for an extension of the deadline for Intermountain to respond to My Health’s complaint

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from June 29, 2015 to July 13, 2015. This is the fourth stipulation and request for an extension of

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this deadline and the fourth overall request for an extension in this case. The initial response
STIPULATION FOR FOURTH EXTENSION
OF TIME TO RESPOND
79286378.1 0033629-00024

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2:15-CV-00073-MMD-CWH

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deadline was February 12, 2015. Pursuant to three earlier stipulations of the parties, the Court

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entered three previous orders extending this deadline, first to March 16, 2015 (Dkt. 11), then to

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April 30, 2015 (Dkt. 21), and then to June 29, 2015. (Dkt. 26).

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After the Court granted these extensions the parties have actively pursued good-faith

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negotiations to settle this dispute. Through counsel, the parties have discussed settlement terms

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in a series of communications and conferences. Although the parties have not been able to reach

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a final settlement agreement yet, the parties remain confident that a final settlement can be

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reached before the proposed extended deadline for Intermountain to file a response, and before

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either party or the Court expends substantial resources on the litigation of this dispute. But the

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parties have been unable to finalize an agreement before the existing June 29 response deadline

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because of scheduling conflicts, the need to further discuss terms for resolving certain claims, and

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the corresponding need for individuals within each party to review and approve settlement terms.

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The parties’ agreed-upon fourth extension promotes judicial economy and ultimately the

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interests of justice by providing additional time to facilitate settlement before the parties and

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Court devote additional resources to the litigation of this matter. The agreed-upon extension

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should not unduly delay the litigation of this matter and, it is expected, should enable the parties

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to efficiently resolve this matter out of court. Accordingly, a fourth extension of the deadline for

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Intermountain to respond to My Health’s complaint to July 13, 2015 is warranted.

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STIPULATION FOR FOURTH EXTENSION
OF TIME TO RESPOND
79286378.1 0033629-00024

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2:15-CV-00073-MMD-CWH

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Dated: June 19, 2015

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PIA ANDERSON DORIUS REYNARD & MOSS, STOEL RIVES LLP
LLC

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/s/ Joseph Pia
Joseph G. Pia (Pro Hac Vice)
[e-mail]
William O. Kimball, NSBN 9301
[e-mail]
222 South Main Street, Suite 1830
Salt Lake City, Utah 84101
Telephone: [phone]
Fax: [phone]

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Counsel for Plaintiff My Health, Inc.
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Respectfully Submitted,

/s/ Hunter Ferguson
Hunter O. Ferguson (Pro Hac Vice)
[e-mail]
600 University Street, Suite 3600
Seattle, WA 98101
Telephone: [phone]
Fax: [phone]
Michael B. Brown, Nevada Bar No. 6577
[e-mail]
10008 SE River Street
Truckee, CA 96161
Telephone: [phone]
Fax: [phone]
Joshua G. Gigger (Pro Hac Vice)
[e-mail]
Marc T. Rasich (Pro Hac Vice)
[e-mail]
201 South Main Street, Suite 1100
Salt Lake City, UT 84111
Telephone: [phone]
Fax: [phone]

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Counsel for Defendant
Intermountain Health Care, Inc.

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IT IS SO ORDERED:

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__________________________
United States District Judge

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June 22, 2015

DATED: _________________

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STIPULATION FOR FOURTH EXTENSION
OF TIME TO RESPOND
79286378.1 0033629-00024

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2:15-CV-00073-MMD-CWH

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CERTIFICATE OF SERVICE

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I hereby certify that on June 19, 2015, I caused a true and correct copy of the foregoing

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STIPULATION FOR THIRD EXTENSION OF TIME TO RESPOND to be served on the parties

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to this matter via the Court’s CM/ECF system.

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/s/Hunter Ferguson
Hunter O. Ferguson

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STIPULATION FOR FOURTH EXTENSION
OF TIME TO RESPOND
79286378.1 0033629-00024

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2:15-CV-00073-MMD-CWH