United States of America, ex rel et al v. Fife Dermatology PC et al

Filing 83

ORDER Granting 82 Stipulation to Extend Deadline to File Reply re 71 Motion for Summary Judgment. Replies due by 6/7/2022. Signed by Judge James C. Mahan on 5/27/2022. (Copies have been distributed pursuant to the NEF - KF)

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Paul Swenson Prior, Esq.
Nevada Bar No. 9324
Hayley J. Cummings, Esq.
Nevada Bar No. 14858
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, NV 89169
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendants Vivida Dermatology f/k/a
Fife Dermatology, PC d/b/a Surgical Dermatology &
Laser Center, Douglas Fife, M.D., and Heather Fife

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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THOMAS MOONEY,

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Plaintiff,

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Case No. 2:17-cv-02191-JCM-EJY
STIPULATION AND ORDER FOR
EXTENSION OF TIME TO FILE
REPLY IN SUPPORT OF
DEFENDANTS’ MOTION FOR
SUMMARY JUDGMENT
[ECF NO. 71]

v.
FIFE DERMATOLOGY, PC, d/b/a
SURGICAL DERMATOLOGY & LASER
CENTER, DOUGLAS FIFE, M.D., and
HEATHER FIFE,
Defendants.

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(Fourth Request)

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Pursuant to Federal Rules of Civil Procedure 6(b)(1) and Local Rule IA 6-1, Defendants

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Vivida Dermatology f/k/a Fife Dermatology, PC d/b/a Surgical Dermatology & Laser Center

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(“Vivida” or the “Practice”), Douglas Fife, M.D. (“Dr. Fife”), and Heather Fife (collectively,

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“Defendants”), by and through their counsel of record, and Plaintiff Thomas Mooney (“Plaintiff”

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and together with Defendants, the “Parties”), by and through his counsel of record, for good cause

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shown, hereby stipulate and agree to extend Defendants’ deadline to file their Reply in Support of

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Defendants’ Motion for Summary Judgment [ECF No. 71] (the “Motion”) by one week, from

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Tuesday, May 31, 2022 to Tuesday, June 7, 2022 for the following reasons:

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Defendants filed the Motion on Friday, February 11, 2022 [ECF No. 70].

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Plaintiff filed his Response to the Motion on Monday, April 25, 2022 [ECF No. 81].

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Defendants’ Reply in Support of the Motion (the “Reply”) is currently due on

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Tuesday, May 31, 2022.

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4.

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additional time in light of deadlines in other matters, an intervening holiday, and to account for pre-

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planned international business travel by the attorney primarily responsible for drafting the Reply.

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L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Snell & Wilmer

Defendants’ counsel has been diligently working on the Reply, but they require

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Defendants further assert that there is good cause for an additional week to file their

Reply to allow for input from key individuals who have been unable to provide input to date.

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No prejudice will result due to the requested one-week extension.

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7.

This extension request is sought in good faith and is not made for the purpose of

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delay.

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THEREFORE, for good cause shown, the Parties respectfully request an extension for

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Defendants to file their Reply in Support of the Motion for Summary Judgment [ECF No. 71] from

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Tuesday, May 31, 2022 to Tuesday, June 7, 2022.

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DATED this 26th day of May, 2022.

DATED this 26th day of May 2022.

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SNELL & WILMER L.L.P.

KEMP & KEMP

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s/ Paul Swenson Prior
Paul Swenson Prior, Esq.
Nevada Bar No. 9324
Hayley J. Cummings, Esq.
Nevada Bar No. 14858
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
Attorneys for Defendants Vivida Dermatology
f/k/a Fife Dermatology, PC d/b/a Surgical
Dermatology & Laser Center, Douglas Fife,
M.D., and Heather Fife

s/ James P. Kemp (with permission)
James P. Kemp, Esq.
Nevada Bar No. 6375
7435 W. Azure Drive, Suite 110
Las Vegas, NV 89130

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Attorneys for Plaintiff Thomas Mooney

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IT IS SO ORDERED.
UNITED STATES DISTRICT JUDGE
DATED:

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May 27, 2022

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CERTIFICATE OF SERVICE

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I, the undersigned, declare under penalty of perjury, that I am over the age of eighteen (18)

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years, and I am not a party to, nor interested in, this action. On this date, I caused to be served a

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true and correct copy of the foregoing STIPULATION AND ORDER FOR EXTENSION OF

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TIME TO FILE REPLY IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY

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JUDGMENT [ECF NO. 71] by method indicated below:

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

BY U.S. MAIL: by placing the document(s) listed above in a sealed envelope with
postage thereon fully prepaid, in the United States mail at Las Vegas, Nevada addressed
as set forth below.

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BY OVERNIGHT MAIL: by causing document(s) to be picked up by an overnight
delivery service company for delivery to the addressee(s) on the next business day.

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BY PERSONAL DELIVERY: by causing personal delivery by, a messenger service
with which this firm maintains an account, of the document(s) listed above to the
person(s) at the address(es) set forth below.

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BY ELECTRONIC SUBMISSION: submitted to the above-entitled Court for
electronic filing and service upon the Court’s Service List for the above-referenced case.



BY EMAIL: by emailing a PDF of the document listed above to the email addresses of
the individual(s) listed below.

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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DATED this 26th day of May, 2022.

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/s/ Maricris Williams
An employee of SNELL & WILMER L.L.P.

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4887-2078-9026.1

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