Opinion
2:19-cv-00329-GMN-EJY
12-29-2022
NAVAJO HEALTH FOUNDATION - SAGE MEMORIAL HOSPITAL, INC. doing business as “Sage Memorial Hospital”; an Arizona non-profit corporation,, Plaintiff, v. RAZAGHI DEVELOPMENT COMPANY, LLC; a Nevada limited liability company doing business as “Razaghi Healthcare”, AHMAD R. RAZAGHI; individually, TAUSIF HASAN; individually, DOES 1-10; ROES A-Z, Defendants. RAZAGHI DEVELOPMENT COMPANY, LLC; an Arizona limited liability company,, Counterclaimant and Third-Party Plaintiff, v. CHRISTI EL-MELIGI; an unmarried person, NETRISHA DALGAI; an unmarried person, STEPHEN D. HOFFMAN and JANE DOE HOFFMAN; a married couple, LEWIS BRISBOIS BISGAARD & SMITH, LLP; a California Limited Liability Partnership,, Third Party Defendants. and NAVAJO HEALTH FOUNDATION - SAGE MEMORIAL HOSPITAL, INC. (doing business as “Sage Memorial Hospital”); an Arizona non-profit corporation, Counterdefendant.
FISHER & PHILLIPS LLP Jeffrey Winchester, NV Bar No. 10279 Pavneet Singh Uppal, AZ SBN 016805 (Admitted Pro Hac Vice) Kris Leonhardt, AZ SBN 026401 (Admitted Pro Hac Vice) Nermana Pehlic, AZ SBN 035240 (Admitted Pro Hac Vice) Attorneys for Third-Party Plaintiff Razaghi Development Company, LLC LEWIS BRISBOIS BISGAARD & SMITH LLP MARC S. CWIK, ESQ. Nevada Bar No. 6946 Attorneys for Third-Party Defendant Lewis Brisbois Bisgaard & Smith LLP Attorneys for Stephen D. Hoffman; and Lewis Brisbois Bisgaard & Smith LLP
FISHER & PHILLIPS LLP
Jeffrey Winchester, NV Bar No. 10279
Pavneet Singh Uppal, AZ SBN 016805 (Admitted Pro Hac Vice)
Kris Leonhardt, AZ SBN 026401 (Admitted Pro Hac Vice)
Nermana Pehlic, AZ SBN 035240 (Admitted Pro Hac Vice)
Attorneys for Third-Party Plaintiff Razaghi Development Company, LLC
LEWIS BRISBOIS BISGAARD & SMITH LLP
MARC S. CWIK, ESQ. Nevada Bar No. 6946
Attorneys for Third-Party Defendant Lewis Brisbois Bisgaard & Smith LLP
Attorneys for Stephen D. Hoffman; and Lewis Brisbois Bisgaard & Smith LLP
STIPULATION TO EXTEND TIME TO RESPOND TO THIRD-PARTY COMPLAINT [FIRST REQUEST]
ELAYNA J. YOUCHAH UNITED STATES MAGISTRATE JUDGE
Third-Party Plaintiff RAZAGHI DEVELOPMENT COMPANY, LLC (hereinafter “RDC”) and Third-Party Defendant LEWIS BRISBOIS BISGAARD & SMITH LLP (hereinafter “Lewis Brisbois”), through their respective counsel, hereby submits the following Stipulation to Extend Time to File Response to Second Amended Third-Party Claims:
RECITALS
WHEREAS, RDC filed its Second Amended Third-Party Claims [ECF No. 217] on November 29, 2022;
WHEREAS, Lewis Brisbois' Las Vegas office received RDC's Summons and Second Amended Third-Party Claims on or about December 9, 2022;
WHEREAS, on December 27, 2022, counsel for Lewis Brisbois contacted counsel for RDC and requested an extension until January 16, 2023 for Lewis Brisbois to file a response to the Second Amended Third-Party Claims, due to pendency of the holiday season and to allow sufficient time to review RDC's allegations;
NOW, THEREFORE, RDC and Lewis Brisbois hereby enter into the following stipulation: STIPULATION
1. Lewis Brisbois shall have up to and including Monday, January 16, 2023, in which to file a response to RDC's Second Amended Third-Party Claims.
2. The stipulated extension of time for Lewis Brisbois to file a response to RDC's Second Amended Third-Party Claims does not operate as any admission against interest by RDC, nor does it operate as a waiver of any objection or defense that Lewis Brisbois may have with regard to the claims set forth in the Second Amended Third-Party Claims [ECF No. 217], to the jurisdiction or venue of this Court, or to service and service of process.
This is Lewis Brisbois' first request for an extension. RDC and Lewis Brisbois' stipulation is not intended for an improper purpose or to cause delay, but is the result of good faith discussions between counsel.
ORDER
IT IS SO ORDERED.