Las Vegas Regional Surgery Center v. Blue Cross of Colorado

Filing 14

ORDER Granting 13 Stipulation to Extend Time Re: 12 Motion to Dismiss. Responses due by 3/19/2018. Replies due by 3/26/2018. Signed by Judge Richard F. Boulware, II on 3/12/2018. (Copies have been distributed pursuant to the NEF - ADR)

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David J. Merrill
Nevada Bar No. 6060
David J. Merrill, P.C.
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145
Telephone: [phone]
E-mail: [e-mail]
Attorney for Defendant CashCall, Inc.

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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LAS VEGAS REGIONAL SURGERY
CENTER, L.P., a Nevada limited partnership,
Plaintiff,

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Stipulation and Order to Extend Time to File
Response to Defendant’s Motion to Dismiss
Plaintiff’s Complaint Pursuant to F.R.C.P.
Rule 12(b)(6)
(First Request)

vs.
BLUE CROSS OF COLORADO, a business
organization, form unknown, and DOES 1–10,

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2:18-CV-00093-RFB-(NJK)

Defendants.
In accordance with LR IA 6-1, LR 7-1(a), and 7-2, the parties stipulate as
follows:
1.

On February 22, 2018, Rocky Mountain Hospital and Medical Service,

Inc. doing business as Anthem Blue Cross and Blue Shield, erroneously named as
Blue Cross of Colorado, filed Defendant’s Notice of Motion and Motion to Dismiss
Plaintiff’s Complaint Pursuant to F.R.C.P. Rule 12(b)(6) (ECF No. 12). In
accordance with LR 7-2(b), the plaintiff, Las Vegas Regional Surgery Center, L.P.,
has up to and including March 8, 2018, to file a response to the motion.
2.

Counsel for Las Vegas Regional Surgery Center serves on the board of

directors of a local non-profit organization. The non-profit’s large annual event
occurred on March 2 through March 4. Counsel was in charge of running the event,
which involved a substantial amount of time before, during, and after the event.

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Hence, Las Vegas Regional Surgery Center’s counsel asked for and

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Blue Cross’s counsel agreed to grant the Las Vegas Regional Surgery Center an

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extension of time until March 19, 2018, to file its response to the motion to dismiss.

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Accordingly, the parties stipulate that Las Vegas Regional Surgery

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Center shall have up to and including March 19, 2018, to file a response to the

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motion. In accordance with LR 7-2, Blue Cross may file a reply in support of the

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motion on or before March 26, 2018.

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5.

the motion to dismiss.

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This is the first request for an extension of time to file an opposition to

DATED this 7th day of March 2018.
DAVID J. MERRILL, P.C.

MESERVE MUMPER & HUGHES LLP

By:

By:

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/s/ David J. Merrill
DAVID J. MERRILL
Nevada Bar No. 6060
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145
[phone]
Attorney for Plaintiff

/s/ Anna Maria Martin
ANNA MARIA MARTIN
Nevada Bar No. 7079
316 California Avenue, #216
Reno, Nevada 89509
[phone]
Attorneys for Defendant

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IT IS SO ORDERED:

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UNITED STATES DISTRICT JUDGE

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DATED: 12th day of March, 2018.

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