Opinion
2:19-cv-00329-GMN-EJY
01-19-2022
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.
Jeffrey Winchester, NV Bar No. 10279 FISHER & PHILLIPS LLP 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) JENNER & BLOCK LLP Douglass A Mitchell Kathleen Bliss, Esq. KATHLEEN BLISS LAW, PLLC David Joel Stander Law Office of David J. Stander LLC Paul S. Padda, Esq. PAUL PADDA LAW, PLLC Christine Logan An employee of Fisher & Phillips LLP
Jeffrey Winchester, NV Bar No. 10279
FISHER & PHILLIPS LLP
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)
JENNER & BLOCK LLP
Douglass A Mitchell
Kathleen Bliss, Esq.
KATHLEEN BLISS LAW, PLLC
David Joel Stander
Law Office of David J. Stander LLC
Paul S. Padda, Esq.
PAUL PADDA LAW, PLLC
Christine Logan An employee of Fisher & Phillips LLP
JOINT STIPULATION TO EXTEND TIME FOR DEFENDANTS TO FILE REPLY IN SUPPORT OF DEFENDANTS' MOTION TO DISMISS SECOND AMENDED COMPLAINT (SECOND REQUEST)
GLORIA M. NAVARRO, DISTRICT JUDGE UNITED STATES DISTRICT COURT
IT IS HEREBY STIPULATED AND AGREED that Defendants Razaghi Development Company, LLC, Ahmad Razaghi, and Tausif Hasan (collectively, “Defendants”) shall have an extension of time, up to and including February 4, 2022, to submit Defendants' reply in support of their Motion to Dismiss Second Amended Complaint (ECF No. 147) therein addressing the arguments raised in Plaintiffs Opposition to Defendants' Second Motion to Dismiss (ECF No. 164).
The parties have so stipulated to this extension request due to defense counsel's concurrent case obligations as well as recent illness in defense counsel's family and office. Unfortunately, the defense counsel primarily responsible for preparing the reply brief in this matter has recently been ill and had illness in her immediate family that has necessitated her attention away from preparing the instant briefing. Further, defense counsel's office has unfortunately experienced several illnesses within the office, including illness of a partner and legal assistant, which has required the remaining attorneys and staff to cover existing and time-sensitive obligations. The additional time requested herein will permit counsel for Defendants to meet other case commitments while addressing the arguments raised in Plaintiff s Opposition to Defendants' Second Motion to Dismiss (ECF No. 164). The parties agree that good cause exists to support this request for Defendants to have additional time, up to and including February 4, 2022, to submit their reply in support of their Motion to Dismiss Second Amended Complaint. This is the second request to extend this deadline.
RESPECTFULLY SUBMITTED.
IT IS SO ORDERED. IT IS FURTHER ORDERED that no further continuances will be granted without a hearing to demonstrate a sufficient basis for further extension of deadlines.
CERTIFICATE OF SERVICE
This is to certify that on January 19, 2022, the undersigned, an employee of Fisher & Phillips LLP, electronically filed the Joint Stipulation to Extend Time for Defendants to File Reply in Support of Defendants' Motion to Dismiss Second Amended Complaint with the U.S. District Court, and a copy was electronically transmitted from the Court to the e-mail address on file for: