USA v. Meridian Surgical Partners, LLC

Filing 77

CASE MANAGEMENT ORDER: Motion to Amend Pleadings due by 8/12/2013. Discovery due by 10/18/2013. Dispositive Motions due by 12/6/2013. Signed by Magistrate Judge E. Clifton Knowles on 6/5/13. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(dt)

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION
UNITED STATES OF AMERICA,
ex rel. THOMAS REED SIMMONS,
Plaintiff–Relator,
v.
MERIDIAN SURGICAL PARTNERS, LLC,
et al.,
Defendants.

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Civil Case No. 3:11-CV-00439
Judge Campbell
Magistrate Judge Knowles

[PROPOSED] CASE MANAGEMENT ORDER
Pursuant to Local Rules 16.01(d), Plaintiff–Relator Thomas Reed Simmons (“Relator”)
and Defendants Meridian Surgical Partners, LLC, Meridian Surgical Partners – Florida II, LLC,
MS Holding Co., Inc., and Treasure Coast Surgery Center, LLC (“Defendants” and, collectively,
the “Parties”) respectfully submit the following Proposed Case Management Order.
I.

Jurisdiction and Venue
Jurisdiction and venue are addressed in the Initial Case Management Order entered in this

case on February 19, 2013 (Docket No. 52).
II.

Plaintiff–Relator’s Theory of the Case
Plaintiff–Relator’s theory of the case is provided in the Initial Case Management Order

(Id. at 2).

III.

Defendants’ Theory of the Case
Defendants’ theory of the case is provided in the Initial Case Management Order (Id. at

3).
IV.

Identification of Issues
All matters except jurisdiction and venue are disputed.

V.

Trial Date
This case is set for a jury trial on May 6, 2014, beginning at 9:00 a.m. (Docket No. 67).

The trial is expected to last five to seven days. The succeeding deadlines are consistent with the
trial date.
VI.

Initial Disclosures
The parties will exchange initial disclosures required by Fed. R. Civ. P. 26(a) no later

than 14 days after entry of this Case Management Order.
VII.

Staging and Timing of Discovery
The following deadlines are established:
a. All fact discovery must be completed by October 18, 2013. No motions concerning
discovery can be filed until after the Parties have conferred in good faith and are unable
to resolve their differences.
The deadline for filing discovery-related motions regarding
fact discovery is October 25, 2013.
b. Relator will disclose his expert witnesses, if any, in accordance with Fed. R. Civ. P.
26(a)(2)(B) by September 27, 2013.
c. Defendant shall disclose its expert witnesses, if any, in accordance with Fed. R. Civ.
P. 26(a)(2)(B) by October 11, 2013.

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d. The Parties will depose all expert witnesses by November 8, 2013.
VIII. Motions to Amend
Any motion to amend the pleadings or join additional parties will be filed by August 12,
2013.
IX.

Dispositive Motions
The deadline for filing all dispositive motions is December 6, 2013. Responses are due

by January 6, 2014, or within 30 days after filing of a dispositive motion. Replies, if any, are due
by January 21, 2014, or within 14 days after any response is filed.
X.

Alternative Dispute Resolution
The Parties are discussing a potential mediation or settlement conference.

XI.

Consent to Trial before the Magistrate Judge
The Parties do not consent.

It is so ORDERED:

______________________________
Hon. E. Clifton Knowles
United States Magistrate Judge

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