Richardson v. U.S. Department of Health and Human Services et al

Filing 21

ORDER Granting 18 Stipulation for Extension of Time re 17 Motion to Dismiss (First Request). Responses due by 8/28/2017. Replies due by 10/4/2017. Signed by Judge James C. Mahan on 8/10/17. (Copies have been distributed pursuant to the NEF - MR)

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1 2 3 4 5 6 7 MARK E. FERRARIO, ESQ. Nevada Bar No. 1625 ERIC W. SWANIS, ESQ. Nevada Bar No. 6840 GREENBERG TRAURIG, LLP 3773 Howard Hughes Parkway Suite 400 North Las Vegas, NV 89169 Telephone: (702) 792-3773 Facsimile: (702) 792-9002 ferrariom@gtlaw.com swanise@gtlaw.com Counsel for Plaintiff 8 IN THE UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 3773 Howard Hughes Parkway Suite 400 North Las Vegas, Nevada 89169 Telephone: (702) 792-3773 Facsimile: (702) 792-9002 GREENBERG TRAURIG, LLP 11 BARBARA D. RICHARDSON, in her capacity as Receiver of Nevada Health Co-Op., Plaintiff, 12 13 14 15 16 17 Case No.: 2:17-cv-00775-JCM-PAL STIPULATION [AND ORDER] TO EXTEND BRIEFING SCHEDULE REGARDING UNITED STATES’ MOTION TO DISMISS COMPLAINT [DKT. # 17] (First Request to Modify Briefing Schedule) v. U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES; CENTERS FOR MEDICARE & MEDICAID SERVICES; THOMAS E. PRICE, M.D., in his capacity as the U.S. Secretary of Health and Human Services; and THE UNITED STATES, 18 Defendants. 19 20 COME NOW Plaintiff, Barbara D. Richardson, in her capacity as Receiver of Nevada 21 Health Co-Op. (“Receiver”), and Defendants, U.S. Department of Health and Human Services, 22 Centers for Medicare & Medicaid Services, Thomas E. Price, M.D., in his capacity as the U.S. 23 Secretary of Health and Human Services, and the United States (“United States” or “HHS”) 24 (together, the “Parties”), by and through their respective counsel of record, and pursuant to LR IA 25 6-1 and in order to comply with Rules 4(i) and 12(a)(2) of the Federal Rules of Civil Procedure, the 26 Parties hereby stipulate to modify the existing briefing schedule in this case with respect to HHS’ 27 Motion to Dismiss the Complaint (“Motion”), filed with this Court on June 29, 2017. See DKT. # 28 13. LV 420960884v3 170678.010100 1 1 In light of the nature of the issues in the case – and to accommodate the Receiver’s 2 counsel’s professional and personal scheduling conflicts, including numerous out-of-state 3 depositions and trial preparations – the Parties stipulate that the Receiver shall have up to and 4 including August 28, 2017 in which to respond to the Motion. 5 6 7 HHS shall have up to and including October 4, 2017 to submit a reply brief in support of the Motion. DATED this 8th day of August, 2017. DATED this 8th day of August, 2017. GREENBERG TRAURIG, LLP UNITED STATES DEPARTMENT OF JUSTICE /s/ Eric W. Swanis MARK E. FERRARIO, ESQ. Nevada Bar No. 1625 ERIC W. SWANIS, ESQ. Nevada Bar No. 6840 3773 Howard Hughes Pkwy., Suite 400N Las Vegas, NV 89169 Counsel for Plaintiff /s/ Frances M. McLaughlin FRANCES M. MCLAUGHLIN TERRANCE A. MEBANE United States Department of Justice Senior Trial Attorney Counsel for United States 8 9 10 3773 Howard Hughes Parkway Suite 400 North Las Vegas, Nevada 89169 Telephone: (702) 792-3773 Facsimile: (702) 792-9002 GREENBERG TRAURIG, LLP 11 12 13 14 15 16 17 18 19 IT IS SO ORDERED. 20 21 ____________________________________ UNITED STATES DISTRICT JUDGE 22 23 August 10, 2017 DATED: ____________________________ 24 25 26 27 28 LV 420960884v3 170678.010100 2

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