Sunrise Hospital and Medical Center, LLC v. Rocky Mountain Hospital and Medical Service, Inc. et al

Filing 51

ORDER granting 50 Stipulation to Extend Discovery Stay. Status Report due by 4/12/2019. Signed by Magistrate Judge George Foley, Jr on 4/1/2019. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:18-cv-00761-RFB-GWF Document 50 Filed 03/29/19 Page 1 of 4

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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James J. Pisanelli, Esq., Bar No. 4027
[e-mail]
Debra L. Spinelli, Esq., Bar No. 9695
[e-mail]
PISANELLI BICE PLLC
400 South 7th Street, Suite 300
Las Vegas, Nevada 89101
Telephone: [phone]
Kevin D. Tessier, Esq. (admitted pro hac vice)
[e-mail]
Karen E. Vaysman, Esq. (admitted pro hac vice)
[e-mail]
REED SMITH LLP
10 South Wacker Drive
Chicago, Illinois 60606-7507
Telephone: [phone]
Attorneys for Rocky Mountain Hospital and Medical
Service, Inc. d/b/a Anthem Blue Cross and Blue Shield and
HMO Colorado Inc. d/b/a HMO Nevada

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SUNRISE HOSPITAL AND MEDICAL
15 CENTER, LLC
Plaintiff,

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vs.

18 ROCKY MOUNTAIN HOSPITAL AND
MEDICAL SERVICE, INC. d/b/a ANTHEM
19 BLUE CROSS AND BLUE SHIELD; HMO
COLORADO INC. d/b/a HMO NEVADA
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Defendants.
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Case No.: 2:18-cv-00761-RFB-GWF

STIPULATION AND ORDER TO EXTEND
DISCOVERY STAY
(First Request)

Plaintiff Sunrise Hospital and Medical Center, LLC (“Plaintiff”) and Defendants Rocky

23 Mountain Hospital and Medical Service, Inc. d/b/a Anthem Blue Cross and Blue Shield and HMO
24 Colorado Inc. d/b/a HMO Nevada (“Defendants”, and collectively with Plaintiff, the “Parties”) submit
25 the following Stipulation and Order to Extend Discovery Stay:
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Case 2:18-cv-00761-RFB-GWF Document 50 Filed 03/29/19 Page 2 of 4

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1.

On March 14, 2019, the Parties submitted a Status Report and Stipulation to Stay

2 Discovery (the “Stipulation”) in which they reported the Parties’ agreement to pursue private
3 mediation and requested to stay discovery for fourteen (14) days to allow for the selection of a
4 mediator and mediation date. (Dkt. 45.) The Parties also stipulated to provide the Court with a status
5 report concerning the scheduling of the mediation and the Parties’ agreement as to an extension of the
6 stay of discovery pending mediation on or before March 29, 2019. (Dkt. 45.) The Court entered the
7 Stipulation and Order on March 15, 2019. (Dkt. 46.)
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2.

The Parties have exchanged proposed mediators and their efforts to select a mediator

9 and mediation date are ongoing. The Parties thus require additional time to complete the scheduling

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 of the mediation and, as such, agree and stipulate to extend the stay of discovery for an additional
11 fourteen (14) days up through and including April 12, 2019.
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3.

The Parties further agree and stipulate that, on or before April 12, 2019, the Parties will

13 provide the Court with a status report concerning the scheduling of the mediation and inform the Court
14 of the Parties’ agreement as to an extension of the stay of discovery pending mediation.
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4.

This is the Parties’ first request to extend the stay of discovery.

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Case 2:18-cv-00761-RFB-GWF Document 50 Filed 03/29/19 Page 3 of 4

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5.

There is good cause to extend the stay. An extension of the stay will allow the Parties

2 to focus their continuing efforts on early resolution in an efficient manner and save the Parties’ time
3 and expense of discovery. Moreover, as no trial in this matter has been set, the requested extension of
4 the stay does not require a change to any trial date. The Parties jointly request to extend the stay.
5 Neither Party to this lawsuit will be prejudiced by the extension of the stay.
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IT IS SO AGREED AND STIPULATED:

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Dated this 29th day of March, 2019

Dated this 29th day of March, 2019

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Lapidus & Lapidus, PLC

REED SMITH LLP

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By: /s/ Daniel C. Lapidus
JIM D. BAUCH
DANIEL C. LAPIDUS
RYAN D. LAPIDUS
Lapidus & Lapidus, PLC
177 South Beverly Drive
Beverly Hills, California 90212

By: /s/ Karen E. Vaysman
KEVIN D. TESSIER
KAREN E. VAYSMAN
10 South Wacker Drive
Chicago, Illinois 60606

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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In Association With:
JAMES J. PISANELLI, ESQ.
DEBRA L. SPINELLI, ESQ.
PISANELLI BICE PLLC
400 South 7th Street, Suite 300
Las Vegas, Nevada 89101

In Association With:
JOSHUA M. DICKEY
BAILEYKENNEDY
8984 Spanish Ridge Avenue
Las Vegas, Nevada 89148-1302

Attorneys for Rocky Mountain Hospital and
Medical Service, Inc. d/b/a Anthem Blue Cross
and Blue Shield and HMO Colorado Inc. d/b/a
HMO Nevada

Attorney for Sunrise Hospital and Medical
Center, LLC

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IT IS SO ORDERED:
UNITED STATE DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE
DATED:

April 1, 2019

CASE NO.: 2:18-cv-00761-RFB-GWF

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