Corbosiero v. Universal Health Services, Inc. et al

Filing 24

ORDER Granting 23 Stipulation to Extend Deadlines. See Order for deadlines. Signed by Magistrate Judge Carl W. Hoffman on 12/1/16. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-00834-JCM-CWH Document 23 Filed 11/30/16 Page 1 of 3

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Julie A. Mersch, Esq.
Nevada Bar No. 004695
LAW OFFICE OF JULIE A. MERSCH
701 S.7th Street
Las Vegas, NV 89101
[phone]
[e-mail]
Attorney for Plaintiff Patricia Corbosiero

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
PATRICIA CORBOSIERO,

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Plaintiff,
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vs.
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UNIVERSAL HEALTH SERVICES, INC., )
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as Plan Administrator for the Universal
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Health Services, Inc. Group Supplemental
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Dependent Life and Accidental Death and
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Dismemberment Plan for employees of
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Universal Health Services, Inc. (“Plans”);
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HARTFORD LIFE AND ACCIDENT
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INSURANCE CO., as Claims Administrator )
for the Plans; DOES I through X, and ROE )
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CORPORATIONS I through X, inclusive,
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Defendants.
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CASE NO.: 2:16-cv-00834-JCM-CWH
STIPULATION AND ORDER TO
EXTEND DEADLINES
(SECOND REQUEST)

IT IS HEREBY STIPULATED by the parties hereto, by and through their
undersigned counsel of record that, pursuant to LR 26-4, the amended Scheduling Order
dated October 17, 2016 (Doc. # 22) be amended as follows:
I.

Case Status
Mediation between Plaintiff and Defendant HARTFORD is currently scheduled for

January 24, 2017. The current scheduling deadlines regarding Plaintiff’s first cause of
action against Hartford will remain in force. Following the filing of the October 17, 2016
Scheduling Order, Plaintiff and Defendant UNIVERSAL HEALTH SERVICES, INC.

STIPULATION AND ORDER TO EXTEND DEADLINES (First Request)

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Case 2:16-cv-00834-JCM-CWH Document 23 Filed 11/30/16 Page 2 of 3

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(UHS) entered into settlement discussions. On October 27, 2016, Plaintiff presented a

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demand to UHS. Defendant UHS is currently considering Plaintiff’s demand, but requires

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additional time for its consideration due to unforeseen delays.

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II.

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Reason for Request for Extension
Plaintiff’s dispositive motion regarding her second cause of action against Defendant

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UHS is currently due by December 2, 2016. Plaintiff and UHS are currently attempting to

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resolve this claim and therefore propose that all briefing deadlines be extended into the new

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year.

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III.

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Proposed Discovery Schedule regarding Plaintiff’s second cause of action against

UHS only:
Plaintiff CORBOSIERO and Defendant UHS propose an approximately 5-week
extension of their remaining deadlines (Doc #22, ¶ III. B):

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Description:

Current Deadline:

Proposed:

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Plaintiff’s Dispositive Motion under
Rule 52 and/or 56

12/02/16

01/09/17

UHS’s opposition to Dispositive
Motion

01/09/17

02/13/17

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Plaintiff’s Reply

01/30/17

03/06/17

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We, the undersigned, represent to the Court that this request for extension is made in

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good faith and not for purposes of delay.
WHEREFORE, the parties jointly request that this Court adopt the proposed

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scheduling as indicated above.

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DATED: November 30, 2016

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LAW OFFICE OF JULIE A. MERSCH
By:

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STIPULATION AND ORDER TO EXTEND DEADLINES (First Request)

/s/ Julie A. Mersch
JULIE A. MERSCH
[e-mail]
Nevada Bar No.: 004695
701 S. 7th Street
Las Vegas, NV 89101
Attorney for Plaintiff Patricia
Corbosiero

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Case 2:16-cv-00834-JCM-CWH Document 23 Filed 11/30/16 Page 3 of 3

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DATED: November 30, 2016

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FORD HARRISON
By:

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/s/ Tiffany D. Downs
TIFFANY D. DOWNS
[e-mail]
271 17th Street NW, Ste. 1900
Atlanta, GA 30363

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Eric Stryker, Esq.
[e-mail]
Nevada Bar No. 5793
Wilson, Elser, Moskowitz,
Edelman & Dicker, LLP
300 S. 4th Street, 11th Floor
Las Vegas, NV 89101

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Attorneys for Defendant UHS

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DATED: November 30, 2016

LEWIS ROCA ROTHGERBER CHRISTIE
By:

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/s/ Ann-Martha Andrews
ANN-MARTHA ANDREWS
[e-mail]
Nevada Bar No. 7585
3993 Howard Hughes Pkwy., Ste. 600
Las Vegas, Nevada 89169
Attorneys for Defendant HARTFORD

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IT IS SO ORDERED.
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December 1, 2016
Dated this ____ day of _________, 2016.

____________________________________
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER TO EXTEND DEADLINES (First Request)

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