Abdou, M.D. et al v. Davita, Inc. et al

Filing 210

ORDER withdrawing 202 Motion to Compel; ORDER denying as moot 203 Motion for Leave to File Excess Pages; Signed by Magistrate Judge Carl W. Hoffman on 11/6/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:16-cv-02597-APG-CWH Document 204 Filed 11/05/18 Page 1 of 3

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JOHN R. BAILEY
Nevada Bar No. 0137
JOSHUA M. DICKEY
Nevada Bar No. 6621
KELLY B. STOUT
Nevada Bar No. 12105
PAUL C. WILLIAMS
Nevada Bar No. 12524
BAILEYKENNEDY
8984 Spanish Ridge Avenue
Las Vegas, Nevada 89148-1302
Telephone: [phone]
Facsimile: 702.562.8821
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants/Counterclaimants
DaVita Inc.; DaVita Medical Holdings, LLC;
and DaVita Medical Management, LLC
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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SHERIF W. ABDOU, M.D. and AMIR S.
BACCHUS, M.D.,

Case No. 2:16-cv-02597-APG-CWH

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STIPULATION AND ORDER TO WITHDRAW
DEFENDANTS/COUNTERCLAIMANTS’
MOTION TO COMPEL PRODUCTION OF
DOCUMENTS [ECF NO. 202]

Plaintiffs,
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v.
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DAVITA INC., HEALTHCARE PARTNERS
HOLDINGS, LLC, and HEALTHCARE
PARTNERS, LLC,

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Defendants.
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________________________________________
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AND RELATED CLAIMS.
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IS HEREBY STIPULATED AND AGREED by and between Plaintiffs/Counterdefendants

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Sherif W. Abdou, M.D. and Amir S. Bacchus, M.D. (“Abdou/Bacchus”) and Defendants/

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Counterclaimants DaVita Inc. (“DaVita”), DaVita Medical Holdings, LLC, f/k/a HealthCare

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Partners Holdings, LLC (“HCP Holdings”), and DaVita Medical Management, LLC, f/k/a

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HealthCare Partners, LLC (“HCP”) (collectively, the “DaVita Parties”) (collectively, the “Parties”),

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through their undersigned counsel, as follows:
Page 1 of 3

Case 2:16-cv-02597-APG-CWH Document 204 Filed 11/05/18 Page 2 of 3

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1.

On October 23, 2018, the DaVita Parties filed their Motion to Compel Production of

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Documents (ECF No. 202) (the “Motion to Compel”), seeking to compel responses to certain

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requests for production propounded to Abdou/Bacchus.

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2.

Subsequently, on October 26, 2018, Abdou/Bacchus produced responsive documents

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to the DaVita Parties’ requests for production, which documents were the subject of the Motion to

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Compel.

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3.

Abdou/Bacchus have represented that, to the best of their knowledge, the documents

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produced (on October 26, 2018) are a complete production of the documents requested in the Motion

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to Compel.

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4.

Based on Abdou/Bacchus’s production and representation, the Parties have agreed to

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stipulate to withdraw the Motion to Compel.

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DATED this 5th day of November, 2018.

DATED this 5th day of November, 2018.

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KOLESAR & LEATHAM

BAILEYKENNEDY

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By: /s/ Matthew T. Dushoff
MATTHEW T. DUSHOFF, ESQ.
Nevada Bar. No. 4975
WILLIAM D. SCHULER, ESQ.
Nevada Bar No. 11271
400 South Rampart Blvd., Suite 400
Las Vegas, Nevada 89145
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiffs Sherif W. Abdou,
M.D. and Amir S. Bacchus, M.D.

By: /s/ Paul C. Williams
JOHN R. BAILEY
JOSHUA M. DICKEY
KELLY B. STOUT
PAUL C. WILLIAMS
Attorneys for Defendants/Counterclaimants
DaVita Inc.; DaVita Medical Holdings, LLC;
and DaVita Medical Management, LLC

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Page 2 of 3

Case 2:16-cv-02597-APG-CWH Document 204 Filed 11/05/18 Page 3 of 3

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ORDER

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IT IS SO ORDERED:

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The Motion to Compel (ECF No. 202) is hereby WITHDRAWN.

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IT IS FURTHER ORDERED that the related motion for leave to file excess
pages (ECF No. 203) is DENIED as moot.

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UNITED STATES MAGISTRATE JUDGE
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Dated:

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Respectfully Submitted by:

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BAILEYKENNEDY

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By: /s/ Paul C. Williams
JOHN R. BAILEY
JOSHUA M. DICKEY
KELLY B. STOUT
PAUL C. WILLIAMS
Attorneys for Defendants/Counterclaimants
DaVita Inc.; DaVita Medical Holdings, LLC;
and DaVita Medical Management, LLC

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November 6, 2018