Inland Northwest Renal Care Group LLC v. WebTPA Employer Services LLC

Filing 95

ORDER granting Parties' 94 Stipulated MOTION Requesting Extension of Case Schedule. The parties' respective summary judgment motions will be due on or before 12/14/2022. Opposition papers will be due on or before 1/13/2023. Repl y papers will be due on or before 1/23/2023.The parties' initial expert disclosures will be due on 1/13/2023, any responsive expert reports will be due on 1/27/2023, and any expert depositions will be completed by 2/10/2023. Signed by Hon. S. Kate Vaughan. (SS)

Case 2:19-cv-01758-JCC-SKV Document 95 Filed 11/17/22 Page 1 of 5

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THE HONORABLE S. KATE VAUGHAN

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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INLAND NORTHWEST RENAL CARE
GROUP, LLC d/b/a NORTHPOINTE
DIALYSIS,
Plaintiff,

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v.
WEBTPA EMPLOYER SERVICES, LLC
and FIRST CHOICE HEALTH NETWORK,
INC.
Defendants.

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No. C19-1758-JCC-SKV
STIPULATED MOTION
REQUESTING EXTENSION OF CASE
SCHEDULE AND PROPOSED ORDER
NOTE ON MOTION CALENDAR:
NOVEMBER 16, 2022

The parties to the above-captioned action, Plaintiff Inland Northwest Renal Care Group,

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LLC d/b/a Northpointe Dialysis (“Northwest”), Defendant WebTPA Employer Services, LLC

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(“WebTPA”), and Defendant First Choice Health Network, Inc. (“First Choice”), hereby

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stipulate and jointly request, for good cause established herein, that the Court establish the
briefing schedule set forth below for the summary judgment motions that the parties expect to
file shortly and to briefly extend the deadline for expert disclosures and expert discovery.
This request will not affect the trial date.
As discussed in further depth below, the parties believe that this briefing schedule will
allow the parties to complete additional discovery that they are currently scheduling and to
accommodate the witnesses’ and parties’ holiday schedules. It will also give the parties
sufficient time to respond to the opposing summary judgment motions.

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STIPULATED MOTION REQUESTING EXTENSION OF
CASE SCHEDULE AND PROPOSED ORDER - 1
C19-1758-JCC-SKV

DORSEY & WHITNEY LLP
701 FIFTH AVENUE, SUITE 6100
SEATTLE, WA 98104-7043
PHONE: [phone]
FAX: [phone]

Case 2:19-cv-01758-JCC-SKV Document 95 Filed 11/17/22 Page 2 of 5

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1.

Under the current briefing scheduling, summary judgment motions must be filed

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on November 23, 2022, with the noting date to be set no later than December 23, 2022. Initial

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expert disclosures are due on November 18, 2022 and rebuttal expert disclosures are due by

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December 9, 2022. The current discovery cutoff is January 13, 2023.

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2.

The parties have been diligently working on various discovery matters. Due to

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the schedules of counsel, the witnesses, and the holidays, they are currently planning to hold

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various depositions in early December. Setting the briefing schedule requested below will

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allow the parties sufficient time to complete these depositions and prepare their summary

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judgment papers.

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3.

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Likewise, the parties believe that it would be most efficient for expert reports

and subsequent expert depositions to occur after fact discovery is complete.

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5.

To address these issues, the parties have agreed to stipulate to the following

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schedule: (1) summary judgment motions will be due on or before December 14, 2022.

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Opposition papers will be due on January 13, 2023. Reply papers will be due on or before

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January 23, 2023.

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6.

The parties likewise propose that initial expert disclosures be due on January 13,

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2023, that any responsive expert reports be due on January 27, 2023, and any expert depositions

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be completed by February 10, 2023.

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7.

This schedule will not interfere with the trial date.

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8.

A Proposed Order is submitted herewith.

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WHEREFORE, and for good cause shown, the parties respectfully request that the Court

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approve the parties’ stipulated schedule for summary judgment briefing, expert disclosures, and

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discovery.

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STIPULATED MOTION REQUESTING EXTENSION OF
CASE SCHEDULE AND PROPOSED ORDER - 2
C19-1758-JCC-SKV

DORSEY & WHITNEY LLP
701 FIFTH AVENUE, SUITE 6100
SEATTLE, WA 98104-7043
PHONE: [phone]
FAX: [phone]

Case 2:19-cv-01758-JCC-SKV Document 95 Filed 11/17/22 Page 3 of 5

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Respectfully submitted on this 16th day of November, 2022.

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DORSEY & WHITNEY LLP
By /s/ Andrew Holly
Benjamin D. Greenberg, WSBA No. 44120
[e-mail]
Andrew Holly, pro hac vice
[e-mail]
Dorsey & Whitney LLP
Columbia Center
701 Fifth Avenue, Suite 6100
Seattle, WA 98104
Telephone: [phone]
Attorney for Defendant WebTPA Employer
Services, LLC
DUANE MORRIS LLP
By /s/ Robert Zaffrann
Robert Zaffrann, pro hac vice
[e-mail]
Adam Santeusanio, pro hac vice
[e-mail]
Duane Morris LLP
100 High Street, Suite 2400
Boston, MA 02110
Tel: [phone]
Attorney for Inland Northwest Renal Care
Group, LLC d/b/a Northpointe Dialysis

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LANE POWELL PC
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By s/ Carin A. Marney
Carin A. Marney, WSBA No. 25132
[e-mail]
Lane Powell PC
1420 Fifth Avenue, Suite 4200
P.O. Box 91302
Seattle, WA 98111-9402
Telephone: [phone]
Facsimile: 206.223.7107
Attorney for Inland Northwest Renal Care
Group, LLC d/b/a Northpointe Dialysis

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STIPULATED MOTION REQUESTING EXTENSION OF
CASE SCHEDULE AND PROPOSED ORDER - 3
C19-1758-JCC-SKV

DORSEY & WHITNEY LLP
701 FIFTH AVENUE, SUITE 6100
SEATTLE, WA 98104-7043
PHONE: [phone]
FAX: [phone]

Case 2:19-cv-01758-JCC-SKV Document 95 Filed 11/17/22 Page 4 of 5

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FOX ROTHSCHILD LLP
By s/ Wendy E. Lyon
Wendy E. Lyon, WSBA No. 34461
[e-mail]
Fox Rothschild LLP
1001 Fourth Ave., Suite 4500
Seattle, WA 98154
Telephone: [phone]
Facsimile: 206.389.1708
Attorney for First Choice Health Network, Inc.

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STIPULATED MOTION REQUESTING EXTENSION OF
CASE SCHEDULE AND PROPOSED ORDER - 4
C19-1758-JCC-SKV

DORSEY & WHITNEY LLP
701 FIFTH AVENUE, SUITE 6100
SEATTLE, WA 98104-7043
PHONE: [phone]
FAX: [phone]

Case 2:19-cv-01758-JCC-SKV Document 95 Filed 11/17/22 Page 5 of 5

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ORDER
The Parties’ Stipulated Motion Requesting Extension of Case Schedule and Proposed
Order is hereby GRANTED, and IT IS HEREBY ORDERED that:

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The parties’ respective summary judgment motions will be due on or before December

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14, 2022. Opposition papers will be due on or before January 13, 2023. Reply papers will be

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due on or before January 23, 2023.

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The parties’ initial expert disclosures will be due on January 13, 2023, any responsive

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expert reports will be due on January 27, 2023, and any expert depositions will be completed

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by February 10, 2023.

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SO ORDERED this 17th day of November, 2022.

A
S. KATE VAUGHAN
United States Magistrate Judge

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STIPULATED MOTION REQUESTING EXTENSION OF
CASE SCHEDULE AND PROPOSED ORDER - 5
C19-1758-JCC-SKV

DORSEY & WHITNEY LLP
701 FIFTH AVENUE, SUITE 6100
SEATTLE, WA 98104-7043
PHONE: [phone]
FAX: [phone]