United States of America et al v. Aledade Inc

Filing 31

ORDER granting Parties' 30 Stipulated MOTION for Extension of Time to Answer Complaint. Defendant's deadline to respond to Plaintiff's Complaint is extended to 7/22/2024. Signed by District Judge Kymberly K. Evanson. (SB)

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The Honorable Kymberly K. Evanson

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UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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UNITED STATES OF AMERICA, ex rel.
KUSHWINDER SINGH,
Plaintiff,
v.
ALEDADE, INC., et. al.,
Defendants.

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CASE NO. 2:21-cv-0410-KKE
STIPULATED MOTION AND ORDER
FOR EXTENSION OF THE TIME
FOR DEFENDANT ALEDADE, INC.
TO RESPOND TO THE COMPLAINT
NOTE ON MOTION CALENDAR:
JUNE 5, 2024

Plaintiff Kushwinder Singh (“Plaintiff”) and Defendant Aledade, Inc. (“Defendant”)
(collectively, “the Parties”), by and through their counsel of record, respectfully submit this
Stipulation, and respectfully request that the Court enter the proposed order for an extension of
time for Defendant to respond to Plaintiff’s Complaint.
1.

On January 10, 2024, the Court unsealed the Amended Complaint against

Defendant in the above-captioned action. (Dkt. No. 24).
2.

On April 8, 2024, Defendant executed a Waiver of the Service of Summons. (Dkt.

No. 27).
3.

Defendant’s deadline to respond to Plaintiff’s Complaint is June 7, 2024.

4.

The Parties are engaged in discussions regarding whether they may streamline and

narrow the litigation.

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STIPULATED MOTION AND ORDER
FOR EXTENSION OF THE TIME TO RESPOND TO COMPLAINT - 1
(No. 2:21-cv-0410-KKE)

Corr Cronin, LLP
1015 Second Avenue, Floor 10
Seattle, WA 98104-1001
[phone]

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5.
extension.

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An extension would further judicial economy and no party will be prejudiced by an

6.

The Parties jointly request a 45-day extension of Defendant’s deadline to respond

to the Complaint to facilitate these discussions.

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7.

Accordingly, the Parties stipulate and respectfully request to extend Defendant’s

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deadline to respond to Plaintiff’s Complaint to July 22, 2024. A proposed order is subjoined

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herewith.

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DATED this 5th day of June, 2024. I certify that this memorandum contains 173 words,
in compliance with the Local Civil Rules.

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Respectfully submitted,

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By:

/s/ Stephen Teller
Stephen Teller
TELLER LAW
300 Lenora St., #1471
Seattle, WA 98121
[phone]
[e-mail]
Attorney for Plaintiff
Kushwinder Singh

By: /s/ Jeffrey B. Coopersmith
Jeffrey B. Coopersmith, WSBA No. 30954
CORR CRONIN, LLP
1015 Second Avenue, Floor 10
Seattle, WA 98104-1001
[phone]
[e-mail]
Brian P. Dunphy (Pro Hac Vice forthcoming)
Nicole E. Henry (Pro Hac Vice forthcoming)
MINTZ, LEVIN, COHN, FERRIS,
GLOVSKY AND POPEO, P.C.
One Financial Center
Boston, MA 02111
[phone]
[e-mail]
[e-mail]
Karen S. Lovitch (Pro Hac Vice forthcoming)
MINTZ, LEVIN, COHN, FERRIS,
GLOVSKY AND POPEO, P.C.
555 12th Street NW
Suite 1100
Washington, DC 20004
[phone]
[e-mail]
Attorneys for Defendant Aledade, Inc.

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STIPULATED MOTION AND ORDER
FOR EXTENSION OF THE TIME TO RESPOND TO COMPLAINT - 2
(No. 2:21-cv-0410-KKE)

Corr Cronin, LLP
1015 Second Avenue, Floor 10
Seattle, WA 98104-1001
[phone]

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ORDER

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IT IS SO ORDERED.

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DATED this 5th day of June, 2024.

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A
Kymberly K. Evanson
United States District Judge

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STIPULATED MOTION AND ORDER
FOR EXTENSION OF THE TIME TO RESPOND TO COMPLAINT - 3
(No. 2:21-cv-0410-KKE)

Corr Cronin, LLP
1015 Second Avenue, Floor 10
Seattle, WA 98104-1001
[phone]