The Physicians Alliance Corporation v. WellCare of Louisiana, Inc. et alMOTION for Leave to File File Reply in Support of WellCare's Motion for Summary Judgment on Plaintiff's Claims Related to The Service FundM.D. La.December 5, 2018UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA THE PHYSICIANS ALLIANCE CIVIL ACTION NO. 3:16-CV-0203 CORPORATION VERSUS JUDGE SHELLY D. DICK WELLCARE HEALTH CARE INSURANCE OF ARIZONA, INC., AND MAGISTRATE JUDGE WELLCARE HEALTH PLANS, INC. RICHARD BOURGEOIS, JR MOTION FOR LEAVE TO FILE REPLY IN SUPPORT OF WELLCARE'S MOTION FOR SUMMARY JUDGMENT ON PLAINTIFF'S CLAIMS RELATED TO THE SERVICE FUND (DOC. 104) NOW INTO COURT, through undersigned counsel, come Defendants, WellCare Health 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 Plaintiff's Claims Related to the Service Fund (Doc. 104) (the "Motion"). In support of their request, WellCare asserts the following: 1 . The Reply, which is attached as Exhibit 1, is comprised of less than 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. 2. Although WellCare's Reply is limited to less than 5 pages of argument, a portion of the signature block and the Certificate of Service cause the Reply to total 6 pages. To the extent the Court would deem this as exceeding the 5 page limit set forth in Local Civil Rule 7 (g) for Reply Case 3:16-cv-00203-SDD-RLB Document 197 12/05/18 Page 1 of 3 briefs, WellCare respectfully requests leave of Court to exceed the 5 page limit and to file its Reply brief totaling 6 pages with the signature block and Certificate of Service. WHEREFORE, for the foregoing reasons, WellCare respectfully requests: 1) leave of Court to tile its attached Reply in support of WellCare's Motion for Summary Judgment On Plaintiffs Claims Related to the Service Fund (Doc. 104); and 2) to the extent the signature block and Certificate of Service cause the Reply to exceed the 5 page limit set forth in Local Civil Rule 7 (g), leave of Court to exceed the page limit and to file its Reply consisting of 6 pages total. Respectfully submitted, BAKER DONELSON BEARMAN CALDWELL & BERKOWITZ, PC By: /s/ Errol J. King ERROL J. KING, JR. Bar Roll No. 17649 LAYNA COOK RUSH, Bar Roll No. 26242 DANIEL P. GUILLORY, Bar Roll No. 31180 ROBERT BLANKENSHIP, Bar Roll No. 33016 450 Laurel Street, 12th Floor Baton Rouge, Louisiana 70801 Telephone: (225) 381-7000 Facsimile: (225) 382-0239 Emails: eking0Thakerdonelson.com lrush(Oakerdonelson.com dguillorv(Oakerdonelson.com rblankenship(Oakerdonelson.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: ccaesar(ii),bakerdonelson.com Case 3:16-cv-00203-SDD-RLB Document 197 12/05/18 Page 2 of 3 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 5 1̀1 day of December, 2018. /y/ Errol J. King Errol J. King Case 3:16-cv-00203-SDD-RLB Document 197 12/05/18 Page 3 of 3