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United States ex rel. Guardiola v. Renown Health

United States District Court, D. Nevada

May 4, 2018

UNITED STATES OF AMERICA ex rel. CECILIA GUARDIOLA, Plaintiff/Relator,
v.
RENOWN HEALTH, RENOWN REGIONAL MEDICAL CENTER, and RENOWN SOUTH MEADOWS MEDICAL CENTER, Defendants.

          William E. Peterson, Nathan G. Kanute, Carrie L. Parker SNELL & WILMER L.L.P. Mitchell R. Kreindler Sharon M. Gurak KREINDLER & ASSOCIATES Counsel for Relator Cecilia Guardiola

          DAYLE ELIESON United States Attorney, ROGER WENTHE Assistant United States Attorney Counsel for United States of America

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

         Pursuant to Local Rule 26-4, Relator Cecilia Guardiola ("Relator") and the United States of America ("Government") by and through their counsel, hereby stipulate and request that this Court extend the discovery deadlines in the above-captioned case by ninety (90) days. The current close of discovery is May 25, 2018, and the Parties seek an extension to August 24, 2018.

         This is the Patties' first request to extend the discovery deadlines. In support of this Stipulation, the Parties state as follows.

         A. REASONS WHY DISCOVERY WAS NOT COMPLETED

         Relator served requests for production and interrogatories on the Government on November 27, 2017. The Government initially responded to the interrogatories and requests for production on January 12, 2018. On January 24, 2018, Relator served her second set of interrogatories on the Government. The Government responded to the second set of interrogatories on March 16, 2018.

         The Parties have met and conferred multiple times regarding the Government's responses to Relator's requests for production and interrogatories. Through the course of those discussions, the Government has agreed to supplement or produce additional documents. Part of that production has required the Government to work with an outside contractor to provide documents, particularly email communications. The Government has initially selected the custodians and search terms to use to retrieve emails that it believes are relevant to the underlying litigation, in particular, the Government's efforts to recover from Renown Health, Renown Regional Medical Center, and Renown South Meadows Medical Center (collectively, "Renown"). Relator has reserved the right to seek emails from additional custodians or using additional search terms.

         Last week, the Government received 11GB of emails from its contractor. The Government requires time to conduct a privilege review of these documents before production. While the Government has suggested that it will provide a rolling production of documents, it has not yet provided a timeline for that production to be completed. Relator will then need time to review the emails that have been produced. It is unclear at this time when the Government will be able to begin its rolling production and how much time Relator may require to complete her review. It is clear, though, that discovery will not be completed by May 25, 2018. Accordingly, there is good cause to grant this extension of the discovery deadlines at this point.

         B. DISCOVERY COMPLETED TO DATE

         The following discovery has been completed:

1. Relator sent interrogatories and requests for production to the Government on November 27, 2017. The Government responded on January 12, 2018.
2. Relator sent her second set of interrogatories on January 24, 2018. The Government responded on March 16, 2018.
3. The Government has received initial search results of email searches from the Government's contractor and is reviewing them for privilege.

         C. DISCOVERY THAT REMAINS TO BE COMPLETED The following ...


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