Page 1 of 2
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
THE PHYSICIANS ALLIANCE * CIVIL ACTION 3:16-cv-00203
CORPORATION, *
* JUDGE SHELLY D. DICK
VERSUS *
* MAGISTRATE JUDGE
WELLCARE HEALTH INSURANCE OF * RICHARD BOURGEOIS, JR.
ARIZONA, INC. AND WELLCARE *
HEALTH PLANS, INC. * SECTION “SDD-RLB”
______________________________________________________________________________
MOTION FOR LEAVE TO FILE REPLY MEMORANDUM TO DEFENDANTS’
OPPOSITION TO PLAINTIFF’S MOTION TO LIMIT OR EXCLUDE TESTIMONY OF
DEFENDANTS’ EXPERT, PHILIP P. MONTELEONE
______________________________________________________________________________
NOW INTO COURT, through undersigned counsel, comes Plaintiff, The Physicians
Alliance Corporation (“Physicians Alliance”), who move this Honorable Court for leave to file its
Reply Memorandum to Defendants’ Opposition to Plaintiff’s Motion to Limit or Exclude
Testimony of Defendants’ Expert Witness, Philip P. Monteleone in accordance Local Civil Rule
7(f), as follows:
1.
On October 26, 2018, Physicians Alliance filed its Motions to Limit or Exclude Testimony
of Defendants’ Expert Witness, Philip P. Monteleone (R. Doc. 115). In response, Defendants filed
their Opposition to Plaintiff’s Motion to Limit or Exclude Testimony of Defendants’ Expert
Witness, Philip P. Monteleone on November 16, 2018. (R. Doc. 136).
2.
Within their Opposition, among other arguments, Defendants argue the appropriateness
and relevancy of the testimony of Philip P. Monteleone, their proffered expert witness. Therefore,
Case 3:16-cv-00203-SDD-RLB Document 198 12/05/18 Page 1 of 2
Page 2 of 2
to counter issues raised therein, Physicians Alliance respectfully requests leave of this Court to file
the attached brief four (4) page Memorandum in Reply.
WHEREFORE, the Plaintiff prays that the present Motion for Leave to file Reply
Memorandum to Defendants’ Opposition to Plaintiff’s Motion to Limit or Exclude Testimony of
Defendants’ Expert Witness, Philip P. Monteleone be GRANTED, thereby permitting Physicians
Alliance file the attached Memorandum in Reply into the record of these proceedings, as per Local
Civil Rule 7(f).
Respectfully submitted:
CLARY, SUBA & ASSOCIATES
/s/ James R. Clary, Jr.
James R. Clary, Jr.
406 North Fourth Street
Baton Rouge, Louisiana 70802
Tel: (225) 926-6788
Fax: (225) 926-8345
Counsel for The Physicians Alliance
Corporation
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
electronically filed with the U.S. District Court for the Middle District of Louisiana, using the
CM/EMF filing system, with the same being automatically forwarded this date to other enrolled
parties through their respective counsel of record as participants in the automatic CM/ECF Filing
System.
Respectfully submitted:
CLARY, SUBA & ASSOCIATES
/s/ James R. Clary, Jr.
Case 3:16-cv-00203-SDD-RLB Document 198 12/05/18 Page 2 of 2
