New Horizon Home Care, LLC v. Northeastern Nevada Regional Hospital ( 2019 )

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 FOR THE STATE OF NEVADA 9 10 || NEW HORIZON HOME CARE, LLC CASE NO. 3:19-CV-00521-RCJ-WGC and GUIDING LIGHT HOSPICE, 11 Plaintiff, 12 vs. ORDER GRANTING STIPULATION AND 13 REQUEST FOR EXTENSION OF TIME NORTHEASTERN NEVADA REGIONAL TO OPPOSE MOTION TO DISMISS AND 14 || HOSPITAL et al MOTION TO STRIKE [FIRST REQUEST] 15 Defendants. / Wy 17 PLAINTIFFS New Horizon Home Care, LLC, and Guiding Light Hospice, Inc., (Plaintiffs”), 18 through its counsel Joseph Alamilla and Stephen S. Kent, and Defendant Northeastern Nevada 19 Regional Hospital (“Defendant”), by and through its counsel Phillip F. Cramer and Ryan T. Holt of the 20 law firm of Sherrard Roe Voigt & Harbison, PLC, Arthur A. Zorio, Esq., and Brownstein, Hyatt, 21 Farber, Schreck LLP, respectfully request this Court permit an extension of time until January 10, 22 2020, for Plaintiffs to file its opposition to Northeastern Nevada Regional Hospital’s Motion to 23 Dismiss and Motion to Strike. 24 1. Plaintiff has been acting diligently since obtaining a copy of the Motions, but two 25 holidays intervene in the time for the opposition. 26 2. This extension request is only for approximately fourteen (14) days, and this is the first 27 request by Plaintiffs for any extension of time; and 28 fff 1 3. Counsel for Defendant Northeastern Nevada Regional Hospital is not opposed to 2 || extend the time as describe above. 3 4 || DATED: December 26, 2019 DATED: December 26, 2019 5 || KENT LAW SHERRARD ROE VOIGT & HARBISON, PLC 6 By: By: /S/ Ryan T. Holt, Esq. 7 8 HEN S. KENT PHILLIP F. CRAMER 201 W. Liberty Street, Suite 320 RYAN T. HOLT 8 Reno, Nevada 89501 150 3®° Avenue South, Ste. 1100 775-324-9800 Nashville, TN 37201 9 ATTORNEYS FOR PLAINTIFFS Telephone: (615) 742-4200 NEW HORIZON HOME CARE, LLC AND GUIDING Facsimile: (615) 742-4539 10 LIGHT HOSPICE. ATTORNEYS FOR DEFENDANTS NORTHEASTERN NEVADA REGIONAL 11 HOSPITAL 12 Pro hac vice applications io be filed 13 || DATED: December 26, 2019 14 || JOSEPH C. ALAMILLA, PLLC BROWNSTEIN, HYATT, FARBER, SCHRECK LLP, 15 || By: /S/Joseph C. Alamilla JOSEPH C. ALAMILLA ARTHUR A. ZORIO, ESQ. 16 9557 South 700 East, Ste 101 5371 Kietzke Lane Sandy, UT 84070 Reno, Nevada 89511 17 801-232-2666 775-324-4100 ATTORNEYS FOR PLAINTIFFS ATTORNEYS FOR DEFENDANTS 18 NEW HORIZON HOME CARE, LLC AND GUIDING NORTHEASTERN NEVADA REGIONAL LIGHT HOSPICE. HOSPITAL. 19 20 21 IT IS SO ORDERED: 23 UNITED STATE STRICT JUDGE 24 DATED: _Decenider 26, 2019. 25 26 27 28 220 =