Finger, M.D. v. Jacobson, et alMOTION for Leave to File Supplemental Memorandum in Opposition to Motion for Summary JudgmentE.D. La.January 21, 20191 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA SIMON FINGER, M.D. v. HARRY R. JACOBSON, M.D., DOUGLAS L. KOPPANG, JR., STEVEN T. JOHNSON, MEDCARE INVESTMENT CORPORATION, AND CARDIOVASCULAR CARE GROUP, INC. ) ) ) ) ) ) ) ) ) ) ) CIVIL ACTION NO.: 17-cv-02893-JTM-DEK SECTION: “H” (3) MOTION FOR LEAVE TO FILE SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO MOTION FOR SUMMARY JUDGMENT Plaintiff SIMON FINGER, M.D., respectfully moves this Court to grant leave to file supplemental briefing in opposition to defendants’ motion for summary judgment (R. Doc. 37). Plaintiff recently retained new counsel, and seek the opportunity for new counsel to supplement the record in opposition to defendants’ dispositive motion. Plaintiff filed a memorandum in opposition to summary judgment on August 14, 2018 (R. Doc. 42), and defendants filed a reply memorandum on August 21, 2018 (R. Doc. 44). That same day, defendants moved for leave to file additional exhibits in support of their motion for summary judgment, which was granted on August 22, 2018 (R. Doc. 46). In the interim time period, plaintiff has been deposed, and new counsel have had the opportunity to review discovery produced by defendants. Leave to file supplemental briefing under these circumstances is reasonable and will not prejudice the defendants—who have already received leave to supplement their motion with additional exhibits. Further, defendants’ motion seeks dismissal of plaintiff’s case, and additional discovery has yielded new facts which will be useful to this Court in rendering its ruling. Case 2:17-cv-02893-JTM-DMD Document 62 Filed 01/21/19 Page 1 of 2 2 WHEREFORE, plaintiff SIMON FINGER, M.D., prays that this Court will grant leave to file supplemental briefing and evidence in opposition to Defendants’ motion for summary judgment. Respectfully submitted, BRUNO & BRUNO, LLP /s/Joseph M. Bruno JOSEPH M. BRUNO (#3604) DANIEL A. MEYER (#33278) 855 Baronne St. New Orleans, LA 70113 Telephone: (504) 525-1335 Facsimile: (504) 562-6775 jbruno@brunobrunolaw.com dmeyer@brunobrunolaw.com CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the above and foregoing upon all counsel of record by placing same in the United States mail, properly addressed and with first-class postage, or by facsimile or other electronic transmission this January 21, 2019. /s/ Daniel A. Meyer Daniel A. Meyer Case 2:17-cv-02893-JTM-DMD Document 62 Filed 01/21/19 Page 2 of 2
