Boston Dental Group, LLC v. Affordable Care, LLC

Filing 98

ORDER granting 97 Stipulation. Proposed Joint Pretrial Order due by 8/9/2018. Signed by Magistrate Judge Carl W. Hoffman on 7/13/2018. (Copies have been distributed pursuant to the NEF - MMM)

SCOTT R. COOK, ESQ.
Nevada Bar No. 005265
JONATHAN D. BLUM, ESQ.
Nevada Bar No. 009515
KOLESAR & LEATHAM
400 South Rampart Boulevard, Suite 400
Las Vegas, Nevada 89145
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
[e-mail]
-andSCOTT J. SLAVICK, ESQ. (IL Bar No. 6256681) – Admitted Pro Hac Vice
SHARON E. CALHOUN, ESQ. (IL Bar No. 6294212) - Admitted Pro Hac Vice
HANNAH Y. JUROWICZ, ESQ. (IL Bar No. 6317050) – Admitted Pro Hac Vice
BARACK FERRAZZANO KIRSCHBAUM & NAGELBERG LLP
200 W. Madison Street, Suite 3900
Chicago, Illinois 60606
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant
AFFORDABLE CARE, LLC
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
BOSTON DENTAL GROUP, LLC, a Nevada
limited liability company,
Plaintiff,

vs.

STIPULATION AND PROPOSED
ORDER TO EXTEND THE PRETRIAL
ORDER DEADLINE TWENTY-EIGHT
(28) DAYS TO AUGUST 9, 2018
(FOURTH REQUEST)

AFFORDABLE CARE, LLC, a North
Carolina limited liability company,
Defendant.
AND RELATED COUNTERCLAIM

1508569.v1

Case No.: 2:16-cv-01636-RFB-CWH

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Pursuant to LR IA 6-1 and 6-2, it is hereby agreed to and stipulated between

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Plaintiff/Counterclaim Defendant Boston Dental Group, LLC (“Boston Dental”), by and

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through its counsel, Michael R. Mushkin & Associates P.C. and Borghese Legal, Ltd., on the

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one hand, and Defendant/Counterclaim Plaintiff Affordable Care, LLC (“Affordable Care”),

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by and through its counsel, Kolesar & Leatham and Barack Ferrazzano Kirschbaum &

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Nagelberg LLP, on the other hand, to a twenty-eight (28) day extension of the July 12, 2018

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Joint Pretrial Order deadline, until August 9, 2018, for the purpose of allowing the parties to

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finalize a settlement agreement, as further set forth herein. This is the fourth stipulation for

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extension of time to extend the Joint Pretrial Order deadline.

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On June 14, 2018, this Court extended the Pretrial Order deadline to July 12, 2018 to

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allow the parties time to finalize a settlement agreement in principle. Since that time, the

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parties have been working to finalize the settlement agreement. The parties are optimistic that

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settlement negotiations will be concluded shortly. Accordingly, the parties seek a brief

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twenty-eight (28) day extension of the Joint Pretrial Order deadline in order to finalize and

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execute the settlement agreement. The litigation of this matter will be best served by the

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proposed extension. There is good cause to grant the parties’ third stipulation for extension of

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time because the parties only seek the extension to allow time to finalize the settlement in

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principle. See Fernandez v. N.V., Case No. 2011 WL 3957612 at *2 (Dist. Nev. Sept. 6,

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2011) (granting motion for extension of time to file pretrial brief because parties engaged in

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settlement negotiations).

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Accordingly, the parties stipulate that the deadline for the Joint Pretrial Order be
extended for twenty-eight (28) days from July 12, 2018 to August 9, 2018.

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IT IS SO STIPULATED.
DATED this 12th day of July, 2018

DATED this 12th day of July, 2018

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KOLESAR & LEATHAM

BORGHESE LEGAL, LTD.

By /s/ Sharon E. Calhoun
By /s/
SCOTT R. COOK, ESQ.
MARK BORGHESE, ESQ.
Nevada Bar No. 005265
Nevada Bar No. 6231
JONATHAN D. BLUM, ESQ.
10161 Park Run Drive, Suite 150
Nevada Bar No. 009515
Las Vegas, Nevada 89145
400 South Rampart Boulevard, Suite 400
[e-mail]
Las Vegas, Nevada 89145
[e-mail]
[e-mail]
SCOTT J. SLAVICK, ESQ. (IL Bar No.
6256681) Admitted Pro Hac Vice
SHARON E. CALHOUN, ESQ. (IL Bar No.
6294212) - Admitted Pro Hac Vice
HANNAH Y. JUROWICZ, ESQ. (IL Bar No.
6317050) – Admitted Pro Hac Vice
BARACK FERRAZZANO KIRSCHBAUM &
NAGELBERG LLP
200 W. Madison Street, Suite 3900
Chicago, Illinois 60606
Telephone: [phone]
[e-mail]
[e-mail]
[e-mail]

MICHAEL R. MUSHKIN, ESQ.
Nevada Bar No. 2421
MICHAEL R. MUSHKIN & ASSOCIATES P.C.
4475 S. Pecos Road
Las Vegas, Nevada 89121
[e-mail]

Attorneys for Plaintiff
Boston Dental Group, LLC

Attorneys for Defendant
Affordable Care, LLC

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ORDER

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IT IS SO ORDERED.
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UNITED STATES MAGISTRATE JUDGE

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DATED:

July 13, 2018

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