Opinion
2:19-cv-00329-GMN-EJY
02-08-2023
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 Kathleen Bliss, Esq. Paul S. Padda, Esq. David Stander, Esq. Douglass A. Mitchell, Esq. Counsel for Plaintiff, Counterdefendant and 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
Kathleen Bliss, Esq.
Paul S. Padda, Esq.
David Stander, Esq.
Douglass A. Mitchell, Esq.
Counsel for Plaintiff, Counterdefendant and 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 DEFENDANTS TO ANSWER PLAINTIFF'S THIRD AMENDED COMPLAINT [ECF NO. 192]
(FIRST REQUEST)
IT IS HEREBY STIPULATED AND AGREED, pursuant to FRCP 6 and LR IA 61 and subject to this Court's approval, that Defendants Razaghi Development Company, LLC, Ahmad Razaghi, and Tausif Hasan (collectively “Defendants”) shall have an extension of time up to and including March 31, 2023 (45 day extension) to respond to Plaintiff's Third Amended Complaint (ECF No. 192) filed on May 20, 2022. On January 30, 2023, the Court recently issued its Ruling on Defendants' Motion to Dismiss the Third Amended Complaint (ECF No. 232), partially granting said motion and triggering the deadline for response to the remaining claims to February 13, 2023.
The parties stipulate that there is good cause for the requested extension due to defense counsels' current case load including Mr. Uppal's upcoming trial in another matter, Defendants' 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. Of note, the Third Amended Complaint is 132 pages, with 278 numbered paragraphs plus an additional 80 pages of subparts. Due to the reasons stated herein, Defendants require additional time to prepare their response thereto. This is the first request to extend Defendants' deadline to respond to the Third Amended Complaint following the Court's Ruling on the Motion to Dismiss (ECF No. 232).
This request is made in good faith and not for the purpose of delay. Neither party will be prejudiced by the requested extension.
For the reasons set forth above, the parties ask the Court to approve this stipulation and allow Defendants up to and including March 31, 2023 to respond to or otherwise answer the Third Amended Complaint (ECF No. 192).
RESPECTFULLY SUBMITTED.
IT IS SO ORDERED.