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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.
                      18
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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
       LLP                                                           -4-
  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 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
       LLP                                                           -5-
  ATTO RNEY S AT LAW
                                                                                     LIMITS AND BRIEFING SCHEDULE
     LOS A NG EL ES


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