IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 20-cv-61007-SINGHAL/VALLE

UNOPPOSED MOTION FOR EXTENSION OF TIME TO PRODUCE DOCUMENTS IN

ACCORDANCE WITH THIS COURT’S ORDER ON DISCOVERY MOTIONS (D.E. 95)

Plaintiff South Broward Hospital District, d/b/a Memorial Healthcare System 

(“Memorial”), respectfully requests a 7-day extension of time, to and including January 14, 2022, 

to produce documents in accordance with this Court’s Order on Discovery Motions (D.E. 95). In 

support thereof, Memorial states as follows:

1. On December 17, 2021, this Court issued its Order on Discovery Motion, which 

granted in part and denied in part Defendants’ Motion to Compel Responses to Interrogatory 21, 

Requests for Production 106, and Request for Production 110 (“Motion”) (D.E. 80).

2. The Court granted Defendants’ Motion “as it relates to RFP 106 and Interrogatory 

21.” (D.E. 95 at 3). Accordingly, the Court ordered that Memorial must produce: “(i) copies of the 

data reports or documents that were used to prepare the Bross Declaration; and (ii) an explanation 

of how [Memorial] and/or Jeffrey Bross calculated the ‘year-to-year weighted average changes in 

SOUTH BROWARD HOSPITAL 

DISTRICT, D/B/A MEMORIAL 

HEALTHCARE SYSTEM, on its own behalf 

and on behalf of other similarly situated 

healthcare facilities, 

Plaintiff,

vs.

ELAP SERVICES, LLC, a Pennsylvania 

limited liability company, and GROUP & 

PENSION ADMINISTRATORS, INC. a 

Texas corporation,

Defendants

____________________________________/

Case 0:20-cv-61007-AHS Document 99 Entered on FLSD Docket 01/06/2022 Page 1 of 3
2

expected payment’ contained in the Bross Declaration.” Id. at 3, 4. The Court ordered that 

Memorial make this production by January 7, 2022. Id. at 4.

3. Memorial respectfully requests a 7-day extension of time, to and including January 

14, 2022, to produce documents in accordance with this Court’s Order on Discovery Motions 

(D.E. 95).

4. Federal Rule of Civil Procedure 6(b)(1)(A) provides that when “an act may or must 

be done within a specified time, the court may, for good cause, extend the time . . . with or without 

motion or notice if the court acts, or if a request is made, before the original time or its extension 

expires.”

5. The period for Memorial to comply with the Court’s Order on Discovery Motions 

has not yet expired.

6. This request is made in good faith and not for the purpose of delay, and no prejudice 

will result from granting the requested extension.

7. Counsel for Memorial has conferred with counsel for Defendants, who does not 

oppose the relief sought herein.

WHEREFORE Plaintiff South Broward Hospital District, d/b/a Memorial Healthcare 

System (“Memorial”), respectfully requests a 7-day extension of time, to and including January 

14, 2022, to produce documents in accordance with this Court’s Order on Discovery Motions 

(D.E. 95).

CERTIFICATE OF GOOD FAITH CONFERRAL

Counsel for Memorial certifies that, pursuant to this Court’s Local Rule 7.1(a)(3), he 

conferred with counsel for Defendants by email. Defendants do not oppose the relief sought 

herein.

Case 0:20-cv-61007-AHS Document 99 Entered on FLSD Docket 01/06/2022 Page 2 of 3
3

Dated: January 6, 2022

/s/Benjamin J. Widlanski

Gail McQuilkin, Esq.

gam@kttlaw.com

Fla. Bar No. 969338

Benjamin J. Widlanski, Esq.

bwidlanski@kttlaw.com 

Fla. Bar No. 1010644

Tal J. Lifshitz, Esq. 

tjl@kttlaw.com

Fla. Bar No. 99519

Michael R. Lorigas, Esq.

mlorigas@kttlaw.com

Fla. Bar. No. 123597

Eric S. Kay, Esq.

ekay@kttlaw.com

Fla. Bar No. 1011803

KOZYAK TROPIN &

THROCKMORTON LLP

2525 Ponce de Leon Blvd., 9th Floor

Coral Gables, FL 33134

(305) 372-1800 

Respectfully submitted,

/s/ Douglas A. Wolfe

Douglas A. Wolfe, Esq.

doug@wolfepincavage.com

Fla. Bar No. 28671

Danya J. Pincavage, Esq.

danya@wolfepincavage.com

Fla. Bar No. 14616

Omar Ali-Shamaa, Esq.

omar@wolfepincavage.com

Fla. Bar No. 121461

WOLFE | PINCAVAGE

7800 SW 57th Ave., Suite 217

Miami, FL 33143

(786) 409-0800

Case 0:20-cv-61007-AHS Document 99 Entered on FLSD Docket 01/06/2022 Page 3 of 3