Letter to Judge McCarthy — U.S. et rel. Integra Med Analytics LLC v. Laufer (July 23, 2026)

Summary

A letter dated July 23, 2026 from Michael Paul Bowen of Herschmann Benson Bowen LLP, filed as Document 247 in the Southern District of New York case Integra Med Analytics LLC v. Laufer, No. 17-cv-9424, and addressed to Judge McCarthy. On behalf of defendants, the letter notifies the Court that defendants are unable to complete production of the patient records ordered in the Court's May 6 Order (382 records) by the August 3, 2026 deadline, the end date for document discovery. It states that defendants have started producing the records on a rolling basis and anticipate producing well over 200 by the deadline. It says records are stored in three off-site storage units with approximately 10,000 boxes, and that counsel will confer before the July 31 court conference. The letter closes with /s/ Michael Paul Bowen.

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             Case 7:17-cv-09424-CS-JCM           Document 247        Filed 07/23/26      Page 1 of 2

                                HERSCHMANN BENSON BOWEN LLP
                                          305 BROADWAY, 7 FLOOR
                                                              TH
                                                                                                       NEW YORK
MICHAEL PAUL BOWEN
                                         NEW YORK, NEW YORK 10007                                      NEW JERSEY
DIRECT DIAL: (917) 341-4611
                                               (212) 226-4226                                            TEXAS
MBOWEN@HBB-FIRM.COM                                                                                    MISSISSIPPI




                                                                    July 23, 2026

        VIA ECF

        Hon. Judith C. McCarthy
        United States Magistrate Judge
        United States District Court
        Southern District of New York
        300 Quarropas St.
        White Plains, NY 10601


                Re: U.S. et rel. Integra Med Analytics LLC v. Laufer, et al., No. 17-cv-9424

        Dear Judge McCarthy:

                On behalf of defendants in this action, we write to notify the Court that, due to
        circumstances beyond their control, defendants are unable to complete production of the 382
        patient records ordered produced by the Court in its May 6 Order by the court-ordered deadline of
        August 3, 2026, the end date for document discovery in this case. Defendants have started
        producing these records on a rolling basis and anticipate producing well over 200 of such records
        by the deadline. Despite best efforts, however, additional time is needed to finish production of
        the balance of the records.

                After the Court ordered the production, defendant Paragon coordinated efforts to locate
        these records from the various defendant Facilities, many of which records are from 2010 and 2011
        – over fifteen years ago. Defendants have multiple storage sites for medical records, including
        each of the eleven Facilities’ building storage areas and three off-site storage units at warehouse
        locations that contain approximately 10,000 boxes of records, with each box containing multiple
        patient records. Paragon assigned one of its full-time employees to oversee the search for and
        production of these records, and a team of employees (eleven in total) has been working diligently
        to locate, and then scan and upload these files, which is a time-intensive process.

                We advised plaintiff’s counsel of this timing issue and will confer with counsel before the
        July 31 court conference about the additional time needed or possible alternatives. We bring this
        matter to the Court’s attention now, however, because, despite acting in good faith to meet the
        court-ordered deadline, defendants are unable to make the complete production of these records
        by that deadline.
    Case 7:17-cv-09424-CS-JCM   Document 247   Filed 07/23/26     Page 2 of 2

HERSCHMANN BENSON BOWEN LLP
Hon. Judith C. McCarthy
July 23, 2026
Page 2

                                        Respectfully submitted,

                                        /s/ Michael Paul Bowen
                                        Michael Paul Bowen


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