Opinion
2:23-cv-00992-MMD-BNW
07-14-2023
Adam D. Chilton Attorneys for Plaintiffs. Charles H. McCrea, Esq., PRHLAW LLC, Thomas F.A. Hetherington, Esq.* Jennifer H. Chung, Esq.* MCDOWELL HETHERINGTON LLP, *Pro hac applications to be submitted Attorneys for BLUE CROSS BLUE SHIELD HEALTHCARE PLAN OF GEORGIA, INC.
Adam D. Chilton Attorneys for Plaintiffs.
Charles H. McCrea, Esq., PRHLAW LLC, Thomas F.A. Hetherington, Esq.* Jennifer H. Chung, Esq.* MCDOWELL HETHERINGTON LLP, *Pro hac applications to be submitted Attorneys for BLUE CROSS BLUE SHIELD HEALTHCARE PLAN OF GEORGIA, INC.
JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND DEFENDANT'S TIME TO RESPOND TO COMPLAINT BY 30 DAYS (FIRST REQUEST)
HON. MIRANDA M. DU, JUDGE.
Plaintiffs Sunrise Mountainview Hospital, Inc. d/b/a Mountainview Hospital and Southern Hills Medical Center, LLC d/b/a Southern Hills Hospital and Medical Center (“Plaintiffs”) and Defendant Blue Cross Blue Shield Healthcare Plan of Georgia, Inc. (“Defendant”) (collectively the “Parties”) hereby stipulate, by and through their respective counsel of record, and subject to the Court's approval, as follows:
1. Plaintiffs filed the Complaint in this action on June 27, 2023 (ECF #1), and Defendant was served with the Summons and Complaint on July 3, 2023.
2. Defendant's current deadline to move, answer or otherwise respond to the Complaint is July 24, 2023.
3. Defendant requires additional time to prepare its response to the Complaint.
4. The Parties therefore agree, subject to the Court's approval, to extend the deadline for Defendant to answer, move or otherwise respond to the Complaint by thirty (30) days, to August 23, 2023.
5. The Parties agree that good cause exists for this extension.
6. This is Defendant's first requested extension.
THE PARTIES HEREBY STIPULATE AND AGREE, subject to the Court's approval, that Defendant's deadline to answer, move or otherwise respond to the Complaint is extended to August 23, 2023.
IT IS SO ORDERED.