Opinion
2:19-cv-00329-GMN-EJY
02-09-2023
NAVAJO HEALTH FOUNDATION - SAGE MEMORIAL HOSPITAL, INC. doing business as “Sage Memorial Hospital”; an Arizona nonprofit corporation Plaintiff, v. RAZAGHI DEVELOPMENT COMPANY, LLC; a Nevada limited liability company doing business as “Razaghi Healthcare”, et al., Defendants.
Allison Kheel, NV Bar No. 12986 FISHER & PHILLIPS LLP Joel Z. Schwarz (with permission) Counsel for Third-Party Defendants Pavneet Singh Uppal, Esq. Kris Leonhardt, Esq. Nermana Pehlic, Esq. Jeffrey D. Winchester, Esq. Counsel for Defendants, Counterplaintiffs, and Third-Party Plaintiffs
Allison Kheel, NV Bar No. 12986
FISHER & PHILLIPS LLP
Joel Z. Schwarz (with permission)
Counsel for Third-Party Defendants
Pavneet Singh Uppal, Esq.
Kris Leonhardt, Esq.
Nermana Pehlic, Esq.
Jeffrey D. Winchester, Esq.
Counsel for Defendants, Counterplaintiffs, and Third-Party Plaintiffs
JOINT STIPULATION TO EXTEND TIME FOR THIRD-PARTY PLAINTIFF RDC TO RESPOND TO THIRD-PARTY DEFENDANTS' MOTION TO DISMISS THIRD-PARTY CLAIM AGAINST LEWIS BRISBOIS AND STEPHEN D. HOFFMAN [ECF NO. 235]
(FIRST REQUEST)
IT IS HEREBY STIPULATED AND AGREED, pursuant to FRCP 6 and LR IA 61 and subject to this Court's approval, that Third-Party Plaintiff Razaghi Development Company, LLC, (“RDC”) shall have an extension of time from February 14, 2023, up to and including March 17, 2023 (30 days) to respond to Third-Party Defendants' Motion to Dismiss RDC's Third-Party Claim Against Lewis Brisbois and Stephen D. Hoffman (ECF No. 235) (the “Motion to Dismiss”) filed on January 31, 2023.
The parties stipulate that there is good cause for the requested extension due to RDC's counsels' current case load including Mr. Uppal's upcoming trial in another matter, RDC's availability to assist in preparing the response, the other currently pending deadlines in this matter, and in consideration of the volume and complexity of the issues in this case, including those raised by the Motion to Dismiss. This is the first request to extend RDC's deadline to respond to the Third-Party Defendants' Motion to Dismiss.
This request is made in good faith and not for the purpose of delay. Neither party will be prejudiced by the requested extension.
Third-Party Defendants Lewis Brisbois Bisgaard & Smith LLP and Stephen D. Hoffman (“Third-Party Defendants”) will be filing a motion to stay discovery with respect to RDC's Third-Party Complaint during the pendency of the Motion to Dismiss. Nothing in this stipulation shall constitute a waiver of any issues or arguments set forth in the Motion to Dismiss or in Third-Party Defendants' forthcoming motion to stay discovery.
For the reasons set forth above, the parties ask the Court to approve this stipulation and allow Third-Party Plaintiff RDC up to and including March 17, 2023 to respond to Third-Party Defendants' Motion to Dismiss.
RESPECTFULLY SUBMITTED.
IT JS SO ORDERED.