Opinion
2:21-cv-01740-RFB-BNW
08-22-2022
REGINA BAILEY, individually and on behalf of a class of similarly situated individuals, Plaintiff, v. HCA, INC.; and VALLEY HEALTH SYSTEM, LLC, Defendants.
SHERI M. THOME, ESQ. Nevada Bar No. 008657, WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP CHARLES E. WEIR (CA Bar No.: 211091) cweir@manatt.com (pro hac vice to be filed) CODY A. DeCAMP* (CA State Bar No.: 311327) cdecamp@manatt.com (pro hac vice to be filed) MANATT, PHELPS & PHILLIPS, LLP Attorneys for Defendant VALLEY HEAL TH SYSTEM, LLC
SHERI M. THOME, ESQ. Nevada Bar No. 008657, WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
CHARLES E. WEIR (CA Bar No.: 211091) cweir@manatt.com (pro hac vice to be filed) CODY A. DeCAMP* (CA State Bar No.: 311327) cdecamp@manatt.com (pro hac vice to be filed) MANATT, PHELPS & PHILLIPS, LLP Attorneys for Defendant VALLEY HEAL TH SYSTEM, LLC
STIPULATION TO EXTEND THE DEADLINE FOR DEFENDANT TO RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT
(First Request)
Pursuant to Local Civil Rule 6-1(a), Defendant Valley Health System, LLC (“Defendant”) and Plaintiff Regina Bailey (“Plaintiff') (collectively, the “Parties”) by and through their undersigned counsel, hereby stipulate and agree as follows:
WHEREAS, Plaintiff initiated this action by filing a complaint on September 21, 2021 against Defendant HCA, Inc.;
WHEREAS, Plaintiff filed a First Amended Complaint naming Valley Health System, LLC as a Defendant on
WHEREAS, Plaintiff served Defendant with the summons and First Amended Complaint on August 4, 2022;
WHEREAS, Defendant HCA, Inc. was voluntarily dismissed without prejudice from these proceedings via a stipulation filed on August 11, 2022, which became the order of the Court on August 12, 2022, WHEREAS, pursuant to Rule 12(a)(1)(A)(i) of the Federal Rules of Civil Procedure, Defendant's current deadline to respond to the First Amended Complaint is August 25, 2022;
WHEREAS, the Parties have agreed to extend the time for Defendant to respond to Plaintiff's First Amended Complaint from August 25, 2022 to October 3, 2022;
WHEREAS, this stipulation and request is being entered into in good faith, and not for reason of delay, as lead counsel for Defendant will be preparing for a trial that is scheduled to proceed in September 2022;
WHEREAS, this is the first stipulation for an extension of time to respond to Plaintiff's First Amended Complaint in this action;
WHEREAS, by entering into this Stipulation, the parties agree that Defendant has not waived its right to bring any motion in response to Plaintiff's claims;
NOW, THEREFORE, the Parties, by their undersigned counsel, hereby stipulate to extend Defendant's deadline to file its response to Plaintiff's First Amended Complaint from August 25, 2022 to October 3, 2022. Defendant shall have up to and including, October 3, 2022, to file a response to Plaintiff's First Amended Complaint.
IT IS SO STIPULATED.
ORDER
GOOD CAUSE SHOWN, IT IS SO ORDERED.