Vece v. Special Administrator of the Estate of Joseph W. Plautz

1 || JOHN R. BAILEY Nevada Bar No. 0137 | JosHUA M. DICKEY Nevada Bar No. 6621 | BAILEY*KENNEDY 8984 Spanish Ridge Avenue | Las Vegas, Nevada 89148-1302 Telephone: 702.562.8820 || Facsimile: 702.562.8821 [email protected] || [email protected] || ANDREW J. ENNIS Missouri Bar No. 57713 | (ADMITTED PRO Hac VICE) POLSINELLI PC | 900 W. 48" Place, Suite 900 Kansas City, Missouri 64112 | Telephone: 816.753.1000 Facsimile: 816.753.1536 | [email protected] = 12 || Attorneys for Defendant Dignity Health Za 13 14 UNITED STATES DISTRICT COURT 15 DISTRICT OF NEVADA || ALLISON R. VECE, individually; KEVIN H.

PHELPS, individually; and GAYLE FEDELE, || individually, Case No.: 2:24-cv-01025-GMN-EJY 18 Plaintiffs, 19 STIPULATION AND ORDER TO EXTEND VS: DEFENDANT DIGNITY HEALTH’S || DOE Special Administrator of the Estate of TIME TO RESPOND TO PLAINTIFFS’ JOSEPH W. PLAUTZ, deceased; DESERET MOTION TO REMAND (ECF 12 | WOMEN’S HEALTH CARE MANAGEMENT, OTION TO ND (ECF No. 12) LLC d/b/a DESERET WOMEN’S CARE; || DIGNITY HEALTH f/k/a ST. ROSE DE LIMA _ | (THIRD REQUEST) HOSPITAL; ROE MEDICAL FACILITIES; || DOES 1 through 10; ROE CORPORATIONS 13 through 20; and ABC LIMITED LIABILITY || COMPANIES 21 through 30, 25 Defendants.

Page 1 of 3 1 Defendant Dignity Health f/k/a St. Rose De Lima Hospital (“Dignity Health”) and Plaintiffs | Allison R. Vece; Kevin H. Phelps; and Gayle Fedele (“Plaintiffs”) (collectively, the “Parties”) | hereby stipulate as follows: 4 1. Plaintiffs’ Motion to Remand (“Motion”) in this action was filed on June 24, 2024 | (ECF No. 12).

6 2. Dignity Health’s current deadline to respond to the Motion is July 26, 2024.

7 3. Plaintiffs’ Petition to Reopen the Estate of Joseph Wheeler Plautz (“Petition”) was | filed on March 21, 2024, in the Eighth Judicial District Court (Case No. P-16-087171-E) □□□□□□□ || Court”).

10 4. The Parties previously stipulated, and the Court ordered, that the deadline to respond || to the Motion be extend from July 8, 2024 to July 26, 2024 (the “First Extension”). = 12 5. Subsequently, the Parties stipulated, and the Court ordered, that the deadline to || respond to the Motion be extend from July 26, 2024 to August 16, 2024 (the “Second Extension”).

72 14 6. The basis for the First Extension and Second Extension was that the decision by the || State Court on the Petition is relevant to the Motion, and it would serve the interests of efficiency | and judicial economy to extend the date for Dignity Health to respond to the Motion until after an || order is entered on the Petition.

18 7. The hearing on the Petition was recently reset for hearing from August 8, 2024, at | 9:00 a.m. to August 29, 2024, at 9:30 a.m.

20 8. Given that the Petition is relevant to the Motion, and that it would serve the interests | of efficiency and judicial economy to extend the date for Dignity Health to respond to the Motion | until after an order is entered on the Petition, the Parties stipulate and agree to extend the deadline | for Dignity Health to file its response to the Motion from August 16, 2024, to September 6, 2024.

24 9. This is Dignity Health’s third requested extension. This stipulation is consistent with || the First Extension and Second Extension, and is made in good faith and not to delay the || proceedings.

Page 2 of 3 ] 10. This stipulation is entered into without waiver of any of the parties’ respective rights, | claims, or defenses.

3 | Dated this 16" day of August, 2024. Dated this 16" day of August, 2024.

4 | BAILEY* KENNEDY CHRISTIAN MORRIS TRIAL ATTORNEYS | By: /s/ Joshua M. Dickey By: 4s/ Victoria R. Allen JOHN R. BAILEY CHRISTIAN M. Morris (NV BAR No. 11218) 6 JOSHUA M. DICKEY VICTORIA R. ALLEN (NV BAR No. 15005) 8984 Spanish Ridge Avenue JAMIE N. MCINELLY (NV BAR No. 15963) 7 Las Vegas, Nevada 89148-1302 SARAH E. DISALVO (NV BAR No. 16398) 8 ANDREW J. ENNIS Attorneys for Plaintiffs Allison R. Vece; Kevin H. Phelps; (ADMITTED PRO HAC VICE) and Gayle Fedele 9 POLSINELLI PC 900 W. 48" Place, Suite 900 10 Kansas City, Missouri 64112 | Attorneys for Defendant Dignity Health 13 IT IS SO ORDERED: Zi 14 ™~ 15 .

6 UNITED)|STATES/MAGISTRATE JUDGE 17 Date: August 16, 2024 Page 3 of 3