The Physicians Alliance Corporation v. WellCare of Louisiana, Inc. et al

MOTION for Leave to File File Reply Memorandum in Support of Defendant's Motion for Summary Judgment on Breach of Contract

M.D. La.December 5, 2018

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA THE PHYSICIANS ALLIANCE CORPORATION VERSUS WELLCARE IIEALTH CARE INSURANCE OF ARIZONA, INC., AND WELLCARE HEALTH PLANS, INC. CIVIL ACTION NO. 3:16-CV-0203 JUDGE SHELLY D. DICK MAGISTRATE JUDGE RICHARD BOURGEOIS, JR MOTION FOR LEAVE TO FILE REPLY IN SUPPORT OF WELLCARE'S MOTION FOR SUMMARY JUDGMENT ON BREACH OF CONTRACT (DOC. 103) NOW INTO COURT, through undersigned counsel, come Defendants, WellCare I lealth Insurance of Arizona, Inc. and WellCare Health Plans, Inc. (collectively, "WellCare"), and, pursuant to Local Civil Rule 7 (g), respectfully request leave of Court to file their Reply in support of WellCare's Motion for Summary Judgment On Breach of Contract (Doc. 103) (the "Motion"). The Reply, which is attached as Exhibit 1, is limited to 5 pages of argument directed pointedly at issues and arguments raised by TPAC in its Opposition to WellCare's Motion. WellCare respectfully submits that the discussion contained in the Reply will assist the Court in reaching a decision on WellCare's Motion. Accordingly, WellCare requests that the Court grant it leave to file its Reply. WHEREFORE, for the foregoing reasons, WellCare respectfully requests leave of Court to file its attached Reply in support of WellCare's Motion for Summary Judgment On Breach of Contract (Doc. 103) Case 3:16-cv-00203-SDD-RLB Document 196 12/05/18 Page 1 of 2 Respectfully submitted, BAKER DONELSON BEARMAN CALDWELL & BERKOWITZ, PC By: /s/ Errol J. King ERROL J. KING, JR. Bar Roll No. 17649 I ,AYNA COOK RUSH, Bar Roll No. 26242 DANIEL P. MALLORY, Bar Roll No. 31180 ROBERT BLANKENSIIIP, Bar Roll No. 33016 450 Laurel Street, 121h Floor Baton Rouge, Louisiana 70801 Telephone: (225) 381-7000 Facsimile: (225) 382-0239 Emails: eking@bakerdonelson.com Irush(c),bakerdonelson.com dguillorv(iaakerdonelson.com rblankenship(&bakerdonelson.com and CRAIG L. CAESAR, Bar Roll No. 19235 201 St. Charles Avenue, Suite 3600 New Orleans, Louisiana 70170 Telephone: (504) 566-5200 Facsimile: (504) 636-4000 Email: ecacsar@bakerdonelson.com Attorneys for WellCare Health Insurance of Arizona, Inc. and WellCare Health Plans, Inc. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing pleading has this date been served on all counsel of record in this proceeding through the Court's ECF filing system. Baton Rouge, Louisiana, this 5th day of December, 2018. /sV Errol ,1 King Errol J. King Case 3:16-cv-00203-SDD-RLB Document 196 12/05/18 Page 2 of 2