Mission Healthcare Servs. v. Battle Born Home Health, LLC

Full title: MISSION HEALTHCARE SERVICES, LLC, a California limited liability company…

Court: United States District Court, District of Nevada

Date published: Oct 17, 2022

3:22-cv-00333-LRH-CLB (D. Nev. Oct. 17, 2022)

Opinion

3:22-cv-00333-LRH-CLB

10-17-2022

MISSION HEALTHCARE SERVICES, LLC, a California limited liability company; and HEALTHY LIVING AT HOME -CARSON CITY, LLC, a Nevada Limited Liability Company, Plaintiffs, v. BATTLE BORN HOME HEALTH, LLC, a Nevada limited liability company; JESSICA CONNANT CRISP, an individual; ANGEL VASQUEZ BARNES, an individual; and JOSEPH BARNES, an individual, Defendants.

John R. Funk, Esq. Jeremy R. Reichenberg, Esq. GUNDERSON LAW FIRM Attorneys for Angel Vasquez Barnes and Joseph Barnes Gregory M. Saylin, Esq. (Pro Hac Vice pending) Kody L. Condos, Esq. (Admitted Pro Hac Vice) HOLLAND & HART LLP Sydney R. Gambee, Esq. (NSB 14201) HOLLAND & HART LLP Attorneys for Plaintiffs Mission Healthcare Services, LLC and Health Living at Home - Carson City, LLC

LARRY R. HICKS UNITED STATES DISTRICT JUDGE

John R. Funk, Esq. Jeremy R. Reichenberg, Esq. GUNDERSON LAW FIRM Attorneys for Angel Vasquez Barnes and Joseph Barnes

Gregory M. Saylin, Esq. (Pro Hac Vice pending) Kody L. Condos, Esq. (Admitted Pro Hac Vice) HOLLAND & HART LLP

Sydney R. Gambee, Esq. (NSB 14201) HOLLAND & HART LLP

Attorneys for Plaintiffs Mission Healthcare Services, LLC and Health Living at Home - Carson City, LLC

ORDER TO CONSOLIDATE AND EXTEND PLAINTIFFS' DEADLINE TO FILE RESPONSES TO DEFENDANTS' MOTIONS TO DISMISS, AND PROPOSED ORDER

FIRST REQUEST

LARRY R. HICKS UNITED STATES DISTRICT JUDGE

STIPULATION

Plaintiffs MISSION HEALTHCARE SERVICES, LLC and HEALTHY LIVING AT HOME - CARSON CITY, LLC, (“Plaintiffs”) and Defendants ANGEL VASQUEZ BARNES and JOSEPH BARNES (together, the “Barnes”), and Defendants JESSICA CONNANT (CRISP) (“Connant”) and BATTLE BORN HOME HEALTH, LLC (“Battle Born,” and together with Plaintiffs, Connant, and the Barnes, the “Parties”), by and through their respective counsel of record, hereby stipulate and agree as follows.

1. Connant and Battle Born filed their Motion to Dismiss, or in the alternative, Motion for a More Definite Statement (the “Battle Born MTD”) on October 3, 2022 (ECF No. 19).

2. Plaintiffs' response to the Battle Born MTD is currently due by October 17, 2022.

3. Plaintiffs and the Barnes have stipulated to extend the deadline for the Barnes to file a response to the Complaint, until and including October 14, 2022, which Order granting said stipulation was entered herein on September 30, 2022 (ECF No. 18).

4. Plaintiffs understand that the Barnes also intend to file a motion to dismiss (the “Barnes MTD”).

5. Based on an anticipated filing date of October 14, 2022, Plaintiffs' response to the anticipated Barnes MTD would be due by October 28, 2022.

6. Due to a family emergency of counsel for Plaintiffs, the Parties agree to consolidate and extend the deadline for Plaintiffs' responses to the Battle Born MTD and the forthcoming Barnes MTD, until and including November 4, 2022.

7. This is Plaintiffs' first request for an extension of time to respond to the Barnes MTD and the Battle Born MTD.

8. This stipulation is made in good faith and not in an attempt to delay proceedings. Dated this 14th day of October, 2022. Dated this 14th day of October, 2022.

ORDER

IT IS SO ORDERED. Plaintiffs shall have until and including November 4, 2022 to file their response(s) to the Barnes MTD and the Battle Born MTD.