United States of America et al v. Careflite et al

MOTION for Extension of Time to File Response/Reply to 68 MOTION

N.D. Tex.August 19, 2016

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORTH WORTH DIVISION UNITED STATES OF AMERICA and THE STATE OF TEXAS ex rel. AIMEE INGOLD and JAMES MARK ROBERTS, Plaintiffs, v. CAREFLITE, f/k/a NORTH CENTRAL TEXAS SERVICES AND QUICK MED CLAIMS, INC., Defendants. § § § § § § § § § § § § § § CIVIL ACTION NO. 4:16-cv-410-O JURY TRIAL DEMANDED ORDER CAME ON TO BE CONSIDERED Plaintiff-Relators’ Unopposed Motion to Extend Time, and after reviewing the Motion and the documents on file, the Court finds that this Motion should be and hereby is in all things GRANTED. IT IS HEREBY ORDERED that Plaintiff-Relators shall have until September 6, 2016 to respond to Defendant CareFlite’s Motion to Defer Discovery Until Motions to Dismiss are Decided. It is FURTHER ORDERED that Defendant’s reply, if any, be filed on or before September 9, 2016. SO ORDERED on this _______ day of August, 2016. _________________________________________ THE HONORABLE JUDGE O’CONNOR UNITED STATES DISTRICT JUDGE Case 4:16-cv-00410-O Document 70 Filed 08/19/16 Page 1 of 4 PageID 396 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORTH WORTH DIVISION UNITED STATES OF AMERICA and THE STATE OF TEXAS ex rel. AIMEE INGOLD and JAMES MARK ROBERTS, Plaintiffs, v. CAREFLITE, f/k/a NORTH CENTRAL TEXAS SERVICES AND QUICK MED CLAIMS, INC., Defendants. § § § § § § § § § § § § § § CIVIL ACTION NO. 4:16-cv-410-O JURY TRIAL DEMANDED PLAINTIFF-RELATORS’ UNOPPOSED MOTION TO EXTEND TIME Plaintiff-Relators, by and through their undersigned counsel, hereby move this Honorable Court to extend their time to respond to Defendant CareFlite’s Motion to Defer Discovery Until Motions to Dismiss are Decided, pursuant to LR 7.1(e). Plaintiff-Relators seek to extend the time to respond twenty-one (21) days, or to September 6, 2016. See LR 7.1(e) (providing that “[a] response and brief to an opposed motion must be filed within 21 days from the date the motion is filed”). Defendant CareFlite does not oppose this motion. The Court’s Order dated August 17, 2016 requires Plaintiff-Relators to respond to CareFlite’s motion on or before August 26, 2016. [See Clerk’s Dkt. No. 69]. The undersigned counsel respectfully asks this Honorable Court to take notice of the fact that Plaintiff-Relators’ undersigned counsel has prepaid vacation scheduled for the week of August 22, 2016. For this reason, Plaintiff-Relators seek an extension. Wherefore, Relators respectfully request that this Honorable Court extend their time to Case 4:16-cv-00410-O Document 70 Filed 08/19/16 Page 2 of 4 PageID 397 3 respond to Defendant CareFlite’s motion and enter the proposed Order, attached hereto as Exhibit A. Respectfully submitted this 18th day of August, 2016. KLINE & SPECTER BY: /s/ David C. Williams, Esquire DAVID C. WILLIAMS, ESQUIRE* State Bar No. 308745 (Pennsylvania) DAVID J. CAPUTO, ESQUIRE State Bar No. 79317 (Pennsylvania) 1525 Locust Street, Nineteenth Floor Philadelphia, Pennsylvania 19102 Telephone: (215) 772-1000 Facsimile: (215) 735-5827 * Admitted Pro Hac Vice WATERS & KRAUS, LLP BY: CHARLES SIEGEL, ESQUIRE LOREN JACOBSON, ESQUIRE CAITLYN SILHAN, ESQUIRE 3219 McKinney Avenue Dallas, Texas 75204 Telephone: (214) 357-6244 JOSEPH TRAUTWEIN & ASSOCIATES, LLC BY: JOSEPH TRAUTWEIN, ESQUIRE 17 Auchy Road Erdenheim, Pennsylvania 19038 Telephone: (215) 764-2301 ATTORNEYS FOR RELATORS CERTIFICATE OF CONFERENCE On the 18th day of August, 2016, I spoke with Defendant’s counsel regarding this Motion, and he does not oppose the relief sought herein. /s/ David C. Williams, Esquire Case 4:16-cv-00410-O Document 70 Filed 08/19/16 Page 3 of 4 PageID 398 CERTIFICATE OF SERVICE On August 18, 2016, I electronically submitted the foregoing document with the clerk of court for the U.S. District Court, Northern District of Texas, using the electronic case filing system of the court. I hereby certify that I have served all counsel and/or pro se parties of record electronically or by another manner authorized by Federal Rule of Civil Procedure 5(b)(2). KLINE & SPECTER, P.C. By: /s/ David C. Williams, Esquire DAVID C. WILLIAMS, ESQUIRE Attorney for the Plaintiff-Relators Dated: August 18, 2016 Case 4:16-cv-00410-O Document 70 Filed 08/19/16 Page 4 of 4 PageID 399