Hometown Health Plan, Inc. et al v. Gateway Health Partners, Inc.

Filing 9

ORDER granting 8 Stipulation to Extend Deadline : Gateway Health Partners, Inc. answer/response to Complaint due by 4/7/2025. Signed by Magistrate Judge Craig S. Denney on 3/10/2025. (Copies have been distributed pursuant to the NEF - DRM)

1 Adam Hosmer-Henner (NSBN 12779)
Katrina Weil (NSBN 16152)
2 MCDONALD CARANO LLP
100 West Liberty Street, Tenth Floor
3 Reno, Nevada 89501
[phone]
4
[e-mail]
5 [e-mail]
6 Attorneys for Plaintiffs
7
UNITED STATES DISTRICT COURT
8
DISTRICT OF NEVADA

9
10

HOMETOWN HEALTH PLAN, INC., a
11 Nevada non-profit corporation and
HOMETOWN HEALTH PROVIDERS
12 INSURANCE COMPANY, INC., a Nevada
non-profit corporation,
13
Plaintiffs,

14
15

Case No.: 3:24-cv-00581-MMD-CSD

ORDER GRANTING STIPULATION
EXTENDING DEADLINE FOR
DEFENDANT TO RESPOND TO
COMPLAINT

vs.
(SECOND REQUEST)

16 GATEWAY HEALTH PARTNERS, INC., a
Delaware corporation; DOES 1 through 10; and
17 ROE ENTITIES 11 through 20, inclusive,
18

Defendants.

19
20

Pursuant to Local Rules IA 6-1 and 7-1, Plaintiffs Hometown Health Plan, Inc. and

21 Hometown Health Providers Insurance Company, Inc. (collectively “Hometown Health”) and
22 Defendant Gateway Health Partners, Inc. (“Gateway”), hereby stipulate, agree, and respectfully
23 request that the Court extend the deadline for Gateway to respond to the Complaint from March 8,
24 2025 to April 7, 2025.
25

Gateway requires additional time to meaningfully analyze the issues presented in this action

26 and to respond. Furthermore, the parties request additional time to discuss the issues presented in
27 this action and to work towards a potential resolution without further litigation. The parties
28 participated in a mediation on February 21st and have continued discussions in good faith following

QB\95092119.1

1 the mediation.1 The parties do not seek this extension for the purposes of delay and this is the second
2 request by Gateway for an extension of time to respond to Hometown Health’s Complaint.
3 Accordingly, the parties request that the Court grant an extension of time to respond to Hometown
4 Health’s Complaint until April 7, 2025.
5
6

DATED this 7th day of March, 2025.

DATED this 7th day of March, 2025.

7

MCDONALD CARANO LLP

QUARLES & BRADY LLP

8

/s/ Mark W. Bina_
Mark W. Bina, Esq. (pro hac vice forthcoming)
300 N. LaSalle Street, Suite 4000
Chicago, Illinois 19428
[phone]
[e-mail]

12

/s/ Adam Hosmer-Henner
Adam Hosmer-Henner, Esq. (NSBN 12779)
Katrina Weil, Esq. (NSBN 16152)
100 West Liberty Street, Tenth Floor
Reno, Nevada 89501
[phone]
[e-mail]
[e-mail]

13

Attorneys for Plaintiffs

9
10
11

15

Brooks T. Westergard (NSBN 14300)
DICKINSON WRIGHT PLLC
100 West Liberty Street, Suite 940
Reno, Nevada 89501
[phone]
[e-mail]

16

Attorneys for Defendant

14

17
IT IS SO ORDERED.

18
19
20

UNITED STATES MAGISTRATE JUDGE

21
22

DATED: ____________________________
March 10, 2025.

23
24
25

1

This Stipulation should not be construed as, nor shall it constitute a waiver of any rights or defenses
26 of any party. The parties agree, however, that this period set aside for mediation shall fully satisfy
any contractual pre-litigation dispute resolution conditions to the extent they have not already been
27 satisfied. Furthermore, the parties agree that this Stipulation does not prevent the parties from further
seeking to extend Gateway’s response date by subsequent stipulation or to prevent Gateway from
28 unilaterally petitioning the Court for additional time if necessary.
2
QB\95092119.1