Opinion
2:23-cv-00992-MMD-BNW
08-30-2023
SUNRISE MOUNTAINVIEW HOSPITAL. INC. D/B/A MOUNTAINVIEW HOSPITAL; and SOUTHERN HILLS MEDICAL CENTER, LLC D/B/A SOUTHERN HILLS HOSPITAL & MEDICAL CENTER, Plaintiffs, v. BLUE CROSS BLUE SHIELD HEALTHCARE PLAN OF GEORGIA, INC., Defendant.
JOSHUA M. DICKEY BAILEY KENNEDY ADAM CHILTON (admitted Pro Hac Vice) POLSINELLI PC Attorney's for Plaintiffs Sunrise MountainView Hospital, Inc. d/b/a MountainView Hospital; and Southern Hills Medical Center, LLC d/b/a Southern Hills Hospital & Medical Center
JOSHUA M. DICKEY BAILEY KENNEDY ADAM CHILTON (admitted Pro Hac Vice) POLSINELLI PC Attorney's for Plaintiffs Sunrise MountainView Hospital, Inc. d/b/a MountainView Hospital; and Southern Hills Medical Center, LLC d/b/a Southern Hills Hospital & Medical Center
PLAINTIFFS SUNRISE MOUNTAINVIEW HOSPITAL, INC. AND SOUTHERN HILLS MEDICAL CENTER, LLC's UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST)
Pursuant to LR LA 6-1 and 6-2, Plaintiffs, Sunrise MountainView Hospital, Inc. d/b/a MountainView Hospital (“MountainView Hospital”), and Southern Hills Medical Center, LLC d/b/a Southern Hills Hospital & Medical Center (“Southern Hills Hospital”), (collectively “Plaintiffs”), by and through then- counsel. Bailey ❖Kennedy, respectfully move this Court for an extension of time to and including Friday, September 15, 2023, to file then' Response to Defendant Blue Cross Blue Shield Healthcare Plan of Georgia, Inc.'s (“Defendant”) Motion to Dismiss Plaintiffs' Complaint. In support of this request, Plaintiffs offer the following:
On August 23, 2023, Defendant filed its Motion to Dismiss [Dkt. No. 17], Pursuant to Local Rule 7-2(b), Plaintiffs' response is currently due on September 6, 2023.
Due to the tune associated with drafting a response to Defendant's Motion to Dismiss and reviewing the voluminous documents that Defendant attached to such motion, and due to the schedule of Plaintiffs' counsel. Plaintiffs need additional time to prepare their response.
Plaintiffs therefore respectfully request an extension of time to and including Friday, September 15, 2023, to file their Response to Defendant's Motion to Dismiss. This is the first motion to extend time to respond to the Motion to Dismiss Plaintiffs' Complaint.
Plaintiffs' request is made in good faith and no party will be prejudiced by the granting of this Motion. Indeed, counsel for Defendant has advised that Defendant does not oppose the relief requested herein.
Additionally, the granting of this Motion will not delay the proceeding as the parties are still actively engaged in drafting discovery requests and moving this case forward.
Consequently, Plaintiffs respectfully suggest that their request for an extension of time to and including Friday, September 15, 2023, to file its Response to Defendant's Motion to Dismiss [Dkt. No. 17, filed August 23, 2023], should be granted.
IT IS SO ORDERED: