Joint Stipulation — Integra v. Providence (C.D. Cal.)
Summary
A joint stipulation and request regarding page limits and the briefing schedule on motions to dismiss, filed October 5, 2018 as Document 47 in United States ex rel. Integra Med Analytics LLC v. Providence Health Services, et al., No. 2:17-cv-01694-PSG-SS, in the U.S. District Court for the Central District of California. It recites that the Second Amended Complaint filed August 10, 2018 (Dkt. 38) includes 142 allegations and two causes of action under the False Claims Act and Anti-Kickback Statute. The parties stipulate that motion-to-dismiss memoranda filed by October 23, 2018 and oppositions may run 35 pages and replies 20 pages, with oppositions due December 3, 2018, replies due December 21, 2018 and a hearing on January 14, 2019. Counsel for the relator, for J.A. Thomas and Associates, Inc. and for the Providence defendants sign, with a proposed order submitted concurrently.
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“Joint Stipulation — Integra v. Providence (C.D. Cal.).”
Original at ecf.cacd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-17-cv-01694-dkt-47-c-d-cal-ecaf16345f/
, SHA-256 13100ace0bd8e6d6b47295494ec2210ab745e1dc1bd9988fd0008ac3ff9e34dc.Full text
Case 2:17-cv-01694-PSG-SS Document 47 Filed 10/05/18 Page 1 of 5 Page ID
#:860
1 HOGAN LOVELLS US LLP
Michael M. Maddigan (Bar No. 163450)
2 David W. Skaar (Bar No. 265377)
1999 Avenue of the Stars, Suite 1400
3 Los Angeles, California 90067
Telephone: (310) 785-4600
4 Facsimile: (310) 785-4601
michael.maddigan@hoganlovells.com
5 david.skaar@hoganlovells.com
6 Attorneys for Defendant
J.A. THOMAS AND ASSOCIATES, INC.
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
11
12 UNITED STATES OF AMERICA, ex Case No. 2:17-cv-01694-PSG-SS
rel. INTEGRA MED ANALYTICS
13 LLC, JOINT STIPULATION AND
REQUEST RE PAGE LIMITS AND
14 Plaintiff, BRIEFING SCHEDULE ON
MOTION TO DISMISS
15 v.
[Proposed] Order submitted
16 PROVIDENCE HEALTH SERVICES, concurrently
et al.,
17
Defendants.
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H OGAN L OVEL LS US STIPULATION RE MOTION TO DISMISS PAGE
LLP
ATTO RNEY S AT LAW
LIMITS AND BRIEFING SCHEDULE
LOS A NG EL ES
Case 2:17-cv-01694-PSG-SS Document 47 Filed 10/05/18 Page 2 of 5 Page ID
#:861
1 JOINT STIPULATION
2 WHEREAS, on August 10, 2018, the Plaintiff filed the Second Amended
3 Complaint (“SAC”) in this matter (Dkt. 38);
4 WHEREAS, each Defendant has executed a waiver of service of the SAC,
5 confirming that October 23, 2018 is their deadline to respond to the SAC (Dkt. 44-
6 45);
7 WHEREAS, the 100-page SAC includes 142 allegations and two causes of
8 action arising under the federal False Claims Act and Anti-Kickback Statute;
9 WHEREAS, pursuant to Local Rule 7-3 and sections 5(b) and 6(a) of the
10 Court’s Civil Standing Order, Defendants will meet and confer with Plaintiff prior
11 to filing any motion in response to the SAC, and will attempt to resolve the issues
12 raised by the contemplated motion;
13 WHEREAS, if the parties are unable to resolve such issues, Defendants
14 intend to file motions to dismiss the SAC;
15 WHEREAS, Defendants will make reasonable efforts to avoid any undue
16 duplication in their respective motions, and will incorporate by reference each
17 other’s arguments as appropriate;
18 WHEREAS, pursuant to section 5(c) of the Court’s Civil Standing Order, the
19 memoranda in support of and in opposition to a motion to dismiss shall not exceed
20 25 pages, and replies shall not exceed 12 pages;
21 WHEREAS, due to the complexity of the allegations and causes of action in
22 the SAC, and the arguments that Defendants anticipate asserting in their motions to
23 dismiss, each Defendant believes in good faith that it cannot adequately respond to
24 the SAC within the 25-page limit;
25 WHEREAS, to the extent that the Court grants Defendants additional pages
26 for their motions to dismiss the SAC, the parties will agree to a commensurate
27 expansion of Plaintiff’s page limit in opposition to the motions;
28 //
H OGAN L OVEL LS US STIPULATION RE MOTION TO DISMISS PAGE
LLP -2-
ATTO RNEY S AT LAW
LIMITS AND BRIEFING SCHEDULE
LOS A NG EL ES
Case 2:17-cv-01694-PSG-SS Document 47 Filed 10/05/18 Page 3 of 5 Page ID
#:862
1 WHEREAS, to the extent that the Court expands Plaintiff’s page limit in
2 opposition to the motions, the parties will agree to a commensurate expansion of
3 each Defendant’s page limit in reply to the oppositions to the motions;
4 WHEREAS, based on Defendants’ filing deadline, Local Rule 6-1, and the
5 Court’s current calendar, the first available hearing date for Defendants’ motions
6 would be Monday, November 26, 2018;
7 WHEREAS, based on the foregoing hearing date and Local Rules 7-9 and 7-
8 10, the Plaintiff’s opposition briefs would be due on November 5, 2018, and
9 Defendants’ reply briefs would be due on November 12, 2018; and
10 WHEREAS, the parties agree that, due to the complexity of the issues raised
11 in the SAC and expected to be raised in the motions, a reasonable extension of time
12 is warranted for both the Plaintiff’s oppositions and Defendants’ replies.
13 NOW, THEREFORE, as a result of the recitals set forth above, and subject to
14 the Court’s approval, the parties stipulate as follows:
15 (1) Any memorandum in support of Defendants’ motions to dismiss, filed
16 on or before October 23, 2018, shall not exceed 35 pages;
17 (2) Plaintiff’s oppositions to Defendants’ motions to dismiss shall be filed
18 on or before December 3, 2018;
19 (3) Any memorandum in support of Plaintiff’s oppositions to Defendants’
20 motions to dismiss shall not exceed 35 pages;
21 (4) Defendants’ replies to Plaintiff’s oppositions to Defendants’ motions
22 to dismiss shall be filed on or before December 21, 2018;
23 (5) Any memorandum in support of Defendants’ replies to Plaintiff’s
24 oppositions shall not exceed 20 pages; and
25 //
26 //
27 //
28 //
H OGAN L OVEL LS US STIPULATION RE MOTION TO DISMISS PAGE
LLP -3-
ATTO RNEY S AT LAW
LIMITS AND BRIEFING SCHEDULE
LOS A NG EL ES
Case 2:17-cv-01694-PSG-SS Document 47 Filed 10/05/18 Page 4 of 5 Page ID
#:863
1 (6) The hearing on Defendants’ motions to dismiss the FAC shall be set
2 for Monday, January 14, 2019, at 1:30 p.m., or thereafter on a date that is
3 convenient for the Court.
4 IT IS SO STIPULATED.
5
Dated: October 5, 2018 MILLER BARONDESS, LLP
6 REID COLLINS & TSAI LLP
7
8 By: /S/ Jeremy H. Wells
9 Jason H. Tokoro
P. Jason Collins
10 Jeremy H. Wells
11 Attorneys for Plaintiff/Relator
INTEGRA MED ANALYTICS LLC
12
13 Dated: October 5, 2018 HOGAN LOVELLS US LLP
14
15 By: /S/ David W. Skaar
16 Michael M. Maddigan
David W. Skaar
17
Attorneys for Defendant
18 J.A. THOMAS AND ASSOCIATES,
INC.
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H OGAN L OVEL LS US STIPULATION RE MOTION TO DISMISS PAGE
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Case 2:17-cv-01694-PSG-SS Document 47 Filed 10/05/18 Page 5 of 5 Page ID
#:864
1 Dated: October 5, 2018 HOOPER, LUNDY & BOOKMAN, PC
2
3 By: /S/ Lloyd A. Bookman
Lloyd A. Bookman
4 Joseph R. LaMagna
Jordan Kearney
5
Attorneys for Defendants
6 PROVIDENCE HEALTH &
SERVICES; PROVIDENCE
7 HEALTH SYSTEM—SOUTHERN
CALIFORNIA; PROVIDENCE
8 HEALTH & SERVICES—
WASHINGTON; PROVIDENCE
9 HEALTH & SERVICES—
OREGON; PROVIDENCE SAINT
10 JOHN’S HEALTH CENTER;
PROVIDENCE HEALTH &
11 SERVICES—MONTANA;
SWEDISH HEALTH SERVICES;
12 and SWEDISH EDMONDS
13
14
15 Attestation
16 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I, David W. Skaar, attest that all of
17 the foregoing signatories concur in this document’s content and have authorized
18 this filing.
19
20 Dated: October 5, 2018 /S/ David W. Skaar
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H OGAN L OVEL LS US STIPULATION RE MOTION TO DISMISS PAGE
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