Medchoice Risk Retention Group, Inc.

Filing 79

ORDER granting ECF No. 78 Joint Stipulation to Continue Deadline to file Plaintiff's reply in support of ECF No. 65 motion for summary judgment. Reply due by 4/16/2018. Signed by Judge Miranda M. Du on 3/28/2018. (Copies have been distributed pursuant to the NEF - LH)

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Michael W. Melendez
Nevada Bar No. 6741
COZEN O’CONNOR
101 Montgomery Street, Suite 1400
San Francisco, California 94104
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Shauna Martin Ehlert
Admitted Pro Hac Vice
COZEN O’CONNOR
999 Third Avenue, Suite 1900
Seattle, Washington 98104
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Designation for Service Only:
Damon Schuetze
Nevada Bar No. 4047
Schuetze & McGaha
601 South Rancho Drive, Suite C-20
Las Vegas, NV 89106
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MEDCHOICE RISK RETENTION GROUP,
INC.

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Plaintiff,

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v.
ROBERT G. RAND, M.D., and RAND FAMILY
CARE LLC
Defendant.

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Case No. 3:16-cv-00418-MMD-VPC
JOINT STIPULATION TO
CONTINUE DEADLINE TO FILE
PLAINTIFF’S REPLY IN SUPPORT
OF ITS MOTION FOR SUMMARY
JUDGMENT [DKT. 65]
[SECOND REQUEST1]

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The reply deadline was continued once to accommodate a stipulated continuance for Defendants’
Response.
JOINT STIPULATION TO CONTINUE DEADLINE TO FILE PLAINTIFF’S REPLY IN SUPPORT OF ITS
MOTION FOR SUMMARY JUDGMENT [DKT. 65]
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34998413\1

JOINT STIPULATION

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Plaintiff MedChoice Risk Retention Group, Inc. and Defendants Robert G. Rand, M.D.

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and Rand Family Care LLC, by and through their respective counsel, hereby stipulate as follows:

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1.

Plaintiff MedChoice filed a Motion for Summary Judgment on February 5, 2018.

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2.

On February 16, 2018, the parties stipulated to an extension of time for newly

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retained counsel Matthew Sharp to respond to MedChoice’s motion.
3.

19, 2018 and extended the reply deadline from March 12, 2018 to April 2, 2018.
4.

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The Court granted the stipulated continuation of deadlines, and Defendants

served their response brief on March 19, 2018.
3.

MedChoice is now requesting additional time to reply in support of its Motion

for Summary Judgment to accommodate client schedules and to the intervening Easter holiday;
4.

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That stipulation extended the response deadline from February 26, 2018 to March

Therefore, the parties jointly request that the Court extend the deadline to file

Plaintiffs’ Reply from April 2, 2018 to April 16, 2018.
5.

The parties submit that this request is not made for the purposes of delay but for

purposes of judicial economy.

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JOINT STIPULATION TO CONTINUE DEADLINE TO FILE PLAINTIFF’S REPLY IN SUPPORT OF ITS
MOTION FOR SUMMARY JUDGMENT [DKT. 65]
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Respectfully submitted this 28th day of March, 2018.

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COZEN O’CONNOR

MATTHEW L. SHARP, LTD.

By:

By: /s/ Matthew L. Sharp (Per Email Authorization)
Matthew L. Sharp
Nevada Bar No. 4746
432 Ridge Street
Reno, NV 89501
Phone: [phone]
Fax: [phone]
Email: [e-mail]

/s/ Shauna Martin Ehlert
Michael W. Melendez,
Nevada Bar No. 6741
575 Market Street, Suite 2200
San Francisco, California 94105
Phone: [phone]
Email: [e-mail]
Shauna Martin Ehlert
Admitted Pro Hac Vice
999 Third Avenue, Suite 1900
Seattle, Washington 98104
Phone: [phone]
Email: [e-mail]

Attorneys for Defendants

Attorneys for Plaintiff

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The deadline for Plaintiffs’ Reply is extended from April 2, 2018 to April 16, 2018.

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IT IS SO ORDERED.

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March 28, 2018
Dated: _________________

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______________________
U.S. District Judge

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JOINT STIPULATION TO CONTINUE DEADLINE TO FILE PLAINTIFF’S REPLY IN SUPPORT OF ITS
MOTION FOR SUMMARY JUDGMENT [DKT. 65]
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34998413\1

Case 3:16-cv-00418-MMD-VPC Document 78 Filed 03/28/18 Page 4 of 4

CERTIFICATE OF SERVICE

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I hereby certify that the above and foregoing document was served on March 28, 2018

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via the Court’s CM/ECF system, to all registered participants as identified on the Notice of

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Electronic Filing.

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/s/ Shauna Martin Ehlert
Shauna Martin Ehlert

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JOINT STIPULATION TO CONTINUE DEADLINE TO FILE PLAINTIFF’S REPLY IN SUPPORT OF ITS
MOTION FOR SUMMARY JUDGMENT [DKT. 65]
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34998413\1