Opinion
2:19-cv-0329-GMN-EJY
02-23-2023
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; Defendants.
KATHLEEN BLISS, ESQ. (NV Bar #7606) KATHLEEN BLISS LAW, PLLC PAUL S. and PADDA, ESQ. (NV Bar #10417) DAVID J. STANDER, ESQ. (Admitted PHV) PAUL PADDA LAW, PLLC and DOUGLASS A. MITCHELL, ESQ. (NV Bar #3775) JENNER & BLOCK, LLP Attorneys for Plaintiff Pavneet S. Uppal, Esq. Kris Leonhardt, Esq. Jeffrey D. Winchester, Esq Counsel for all named Defendants
KATHLEEN BLISS, ESQ. (NV Bar #7606) KATHLEEN BLISS LAW, PLLC PAUL S. and PADDA, ESQ. (NV Bar #10417) DAVID J. STANDER, ESQ. (Admitted PHV) PAUL PADDA LAW, PLLC and DOUGLASS A. MITCHELL, ESQ. (NV Bar #3775) JENNER & BLOCK, LLP Attorneys for Plaintiff
Pavneet S. Uppal, Esq. Kris Leonhardt, Esq. Jeffrey D. Winchester, Esq Counsel for all named Defendants
JOINT STIPULATION TO EXTEND CHRISTIE EL-MELIGI AND NETRISHA DALGAI'S TIME TO RESPOND TO MOTION TO' TRANSFER VENUE (FIRST REQUEST)
Pursuant to Federal Rule of Civil Procedure (“FRCP”) 6 and the Court's Local Rule of Civil Practice 7-1, the parties hereby stipulate, subject to the Court's approval, to permit Christi El-Meligi and Netrisha Dalgai (Third Party Defendants) additional time, to and until March 10, 2023 to respond to Defendants' motion to transfer venue (ECF No. 245) to the District of Arizona. Currently, a response to the pending motion is due on February 24, 2023.
Good cause exists to support this request. Undersigned counsel for Mss. El-Meligi and Dalgai have notified counsel for Defendants that their clients are in the process of retaining new counsel and that they will need additional time to respond to the pending motion.
Counsel for the respective parties have communicated regarding this Stipulation and agree that an extension of time of two additional weeks, to and until March 10, 2023, to respond to the pending motion to transfer is appropriate under the circumstances.
The parties respectfully request the Court approve this Stipulation.
IT IS SO ORDERED