October 18, 2013
UNITED STATES OF AMERICA ET AL. Plaintiffs,
NORTH EAST MEDICAL SERVICES, INC. Defendant. NORTH EAST MEDICAL SERVICES, INC., Plaintiff,
CALIFORNIA DEPARTMENT OF HEALTHCARE SERVICES, et al., Defendant. NORTH EAST MEDICAL SERVICES, INC., Plaintiff,
CALIFORNIA DEPARTMENT OF HEALTHCARE SERVICES, et al., Defendant. LA CLINICA DE LA RAZA, INC., Plaintiff,
CALIFORNIA DEPARTMENT OF HEALTHCARE SERVICES, et al., Defendant.
FELDESMAN TUCKER LEIFER FIDELL LLP, By: /s/ Marisa B. Guevara ,
James L. Feldesman, Matthew S. Freedus, Marisa B. Guevara, Nicole M. Bacon, Robert F. Kane, LAW OFFICES OF ROBERT F. KANE, Attorneys for North East. Medical Services, Inc. and La Clinica de la Raza, Inc.,
STUART F. DELERY, Assistant Attorney General, MELINDA HAAG, United States Attorney,
ILA C. DEISS, MELANIE L. PROCTOR, Assistant United States Attorneys, San Francisco, California, MICHAEL D. GRANSTON, DANIEL R. ANDERSON, EDWARD C. CROOKE, MEREDITH L. TOOLE, Civil Division, U.S. Department of Justice, Attorneys, Civil Division, United States Department of Justice, Washington, D.C., Attorneys for the United States.
KAMALA D. HARRIS, Attorney General for the State of California.
LORA FOX MARTIN, Deputy Attorney General, California Attorney General's Office, Bureau of Medi-Cal Fraud and Elder Abuse, San Diego, California,
HADARA R. STANTON, Deputy Attorney General, San Francisco, California,
JOSHUA SONDHEIMER, Deputy Attorney General, San Francisco, California, Attorneys for the State of California.
STIPULATED REQUEST FOR ORDER CHANGING TIME; AND [PROPOSED] ORDER
CLAUDIA WILKEN, Chief District Judge.
Pursuant to Local Civil Rules 6-2 and 7-12, the parties hereby stipulate, subject to approval of the Court, to the following:
1. On April 11, 2013, the Court set a consolidated summary judgment motion briefing schedule for the above-captioned related cases, with a November 14, 2013 hearing date.
2. On September 18, 2013, the parties filed a stipulated request for an order changing the briefing schedule to allow the parties additional time to streamline discovery and stipulate to certain material facts and documents.
3. On September 19, 2013, the Court granted the parties' stipulated request for order changing time and reset the hearing date to November 21, 2013.
4. Pursuant to the stipulation and order, the parties have continued to meet and confer regarding the schedule.
5. On September 26, 2013, the government parties filed their consolidated motion for summary judgment.
6. On October 14, 2013, North East Medical Services filed a motion for extension of time.
7. The government parties dispute that the 30(b)(6) deposition is a necessary prerequisite to NEMS filing its motion. However, after additional conversations, the government parties anticipate identifying and producing a witness from HHS to testify on the topics identified in NEMS' Amended Notice of Deposition (ECF No. 104-6) on or before October 28, 2013.
8. NEMS hereby withdraws its request for enlargement of time (ECF No. 104), and the parties jointly request the following changes to the briefing schedule:
Pursuant to stipulation, it is SO ORDERED.