REACH Air Medical Services LLC v. Kaiser Foundation Health Plan Inc. et al
| REACH Air Medical Services LLC |
| Kaiser Foundation Health Plan Inc. and C2C Innovative Solutions, Inc. |
| America's Health Insurance Plans |
| 3:2022cv01153 |
| October 26, 2022 |
| US District Court for the Middle District of Florida |
| Timothy J Corrigan |
| Laura Lothman Lambert |
| Joel B Toomey |
| Other Statutory Actions |
| None |
Docket Report
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This docket was last retrieved on November 20, 2023. A more recent docket listing may be available from PACER.
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| Filing 68 NOTICE by Kaiser Foundation Health Plan Inc. re 67 Second Notice to Counsel of Local Rule: Notice Re Update Of Counsel Information For Kaiser Foundation Health Plan, Inc. (Burns, John) |
| Filing 67 SECOND NOTICE TO COUNSEL Barclay R. Nicholson and Erica C. Gibbons Local Rule 2.01(c), Special Admission of Non-Resident Lawyer - File a Motion to Appear Pro Hac Vice. Co-counsel with filing rights may electronically file the motion on behalf of the non-resident lawyer or the motion may be filed on paper; Pay the Special Admission Fee; Submit a Pro Hac Vice E-File Registration through PACER. Visit www.flmd.uscourts.gov/for-lawyers for details (Signed by Deputy Clerk). (ARL) |
Filing 66
ENDORSED ORDER re Med-Trans and Reach Air's Notice of Intent to Stand on Existing Complaints filed in 3:22-cv-1077 and 3:22-cv-1153. In each case, no later than 12/8/2023, Plaintiff shall file a proposed final order for the Court's consideration after conferring with opposing counsel. Signed by Judge Timothy J. Corrigan on 11/20/2023. (KSM)
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| Filing 65 NOTICE by REACH Air Medical Services LLC of Intent to Stand on Existing Complaint (Schramek, Adam) |
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Filing 64
ORDER on all pending motions. See Order for details. Signed by Judge Timothy J. Corrigan on 11/1/2023. (RMV)
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| Filing 63 RESPONSE re #61 Notice of filing supplemental authority, #62 Response filed by Kaiser Foundation Health Plan Inc. (Attachments: #1 Exhibit A)(Keshavarzi, Mohammad) Modified text on 9/20/2023 (MCB). |
| Filing 62 RESPONSE re #61 Notice of filing supplemental authority filed by REACH Air Medical Services LLC. (Russell, Lanny) |
| Filing 61 NOTICE of supplemental authority re #30 MOTION to Dismiss Complaint by Kaiser Foundation Health Plan Inc. (Burns, John) Modified text on 9/15/2023 (BD). |
| Filing 60 STATUS report [Joint] by Kaiser Foundation Health Plan Inc. (McKisson, Megan) Modified text on 8/4/2023 (KME). |
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Filing 59
ORDER directing the parties to jointly file a status report re settlement no later than 8/4/2023. Signed by Judge Timothy J. Corrigan on 7/24/2023. (RMV)
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| Filing 57 REPLY to #52 SUPPLEMENTAL Brief to #30 MOTION to Dismiss Complaint filed by Kaiser Foundation Health Plan Inc. (Keshavarzi, Mohammad) Modified text on 6/20/2023 (BD). |
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Filing 56
ENDORSED ORDER granting #55 Defendant Kaiser Foundation Health Plan Inc's Amended Motion for Leave to File Reply. Kaiser may file a reply of no more than 7 pages no later than 6/16/2023. Signed by Judge Timothy J. Corrigan on 6/8/2023. (RMV)
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| Filing 55 Amended MOTION for Leave to File Reply To Plaintiff's #52 Supplemental Brief by Kaiser Foundation Health Plan Inc. (McKisson, Megan) Modified text on 6/8/2023 (BD). |
| Filing 54 NOTICE TO COUNSELS Barclay R. Nicholson and Erica C. Gibbons of Local Rule 2.01(c), Special Admission of Non-Resident Lawyer - File a Motion to Appear Pro Hac Vice. Co-counsel with filing rights may electronically file the motion on behalf of the non-resident lawyer or the motion may be filed on paper; Pay the Special Admission Fee; (Signed by Deputy Clerk). (BD) |
| Filing 53 MOTION for Leave to File Reply To Plaintiff's #52 Supplemental Brief to #30 MOTION to Dismiss Complaint and to Strike Claim for Attorney's Fees by Kaiser Foundation Health Plan Inc. (McKisson, Megan) Modified text on 6/6/2023 (BD). |
| Filing 52 SUPPLEMENTAL Brief re #30 MOTION to Dismiss Complaint and to Strike Claim for Attorney's Fees filed by REACH Air Medical Services LLC. (Attachments: #1 Exhibit Aetna Transcript Excerpts, #2 Exhibit Envision Declaration Excerpts)(Schramek, Adam) (Modified on 5/30/2023, to edit text) (BGR). |
| Filing 51 TRANSCRIPT of Motion Hearing held on May 16, 2023 before Judge Timothy J. Corrigan. Court Reporter/Transcriber: Shannon M. Bishop, RDR, CRR, CRC. Email address: dsmabishop@yahoo.com. Telephone number: (904)549-1307. NOTICE TO THE PARTIES - The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such notice is filed, the transcript may be made remotely available to the public without redaction after ninety (90) calendar days. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER or purchased through the Court Reporter. Redaction Request due 6/9/2023. Redacted Transcript Deadline set for 6/20/2023. Release of Transcript Restriction set for 8/17/2023. (SB) |
| Filing 50 RESPONSE in Opposition re #48 MOTION for Leave to Submit Amicus Curiae Brief in Support of Defendant Kaiser Foundation Health Plain, Inc.'s #30 Motion to Dismiss filed by REACH Air Medical Services LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Schramek, Adam) |
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Filing 49
ENDORSED ORDER granting #47 Amicus Curiae America's Health Insurance Plans's Unopposed Motion for Counsel to Appear Pro Hac Vice. If Hyland Hunt, Esq., has not already done so, she shall expeditiously register for a login and password for electronic filing at the Court's website at www.flmd.uscourts.gov. Signed by Magistrate Judge Joel B. Toomey on 5/1/2023. (TSP)
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| Filing 48 MOTION for Leave to Submit Amicus Curiae Brief in Support of Defendant Kaiser Foundation Health Plain, Inc.'s #30 Motion to Dismiss by America's Health Insurance Plans. (Attachments: #1 Amicus Brief)(Burns, Thomas) Modified text on 5/1/2023 (BD). |
| Filing 47 Unopposed MOTION for Hyland Hunt to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-20778252 for $150 by America's Health Insurance Plans. (Burns, Thomas) Motions referred to Magistrate Judge Joel B. Toomey. |
| Filing 46 REDACTED TRANSCRIPT of Telephonic Preliminary Pretrial Conference held on January 17, 2023 before Judge Timothy J. Corrigan, re #34 Transcript. Court Reporter/Transcriber: Shannon M. Bishop, RDR, CRR, CRC. Email address: dsmabishop@yahoo.com. Telephone number: (904)549-1307. (SB) |
| Filing 45 REPLY to Response to Motion re #30 MOTION to Dismiss Complaint and to Strike Claim for Attorney's Fees filed by Kaiser Foundation Health Plan Inc.. (Dodd, Christian) |
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Filing 44
ENDORSED ORDER granting to the extent stated below #39 Plaintiffs' Opposed Motion to Partially Redact Telephonic Preliminary Pretrial Conference Transcript, and denying as moot #43 Plaintiffs' Unopposed Motion for Leave to File a Consolidated Reply Brief on Transcript Redaction. The Court is satisfied that Plaintiffs have shown good cause for redaction of the subject limited portions of the transcript (Doc. 34), as modified below. Assuming the common law right of access applies, Plaintiffs have overcome it by showing that the subject information is likely commercially valuable to competitors and insurers. (Doc. 39 at 4-6; Doc. 39-1.) Based on the arguments presented, the Court finds that Plaintiffs' interest in keeping the information confidential outweighs any public interest in accessing the information. See Romero v. Drummond Co., 480 F.3d 1234, 1246 (11th Cir. 2007). However, the Court Reporter is directed to redact only the following portions of the subject transcript: the number before the word "percent" on page ten, lines six and fifteen, and on page eleven, line six. Signed by Magistrate Judge Joel B. Toomey on 3/7/2023. (JDM)
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| Filing 43 Unopposed MOTION for Leave to File a Consolidated Reply Brief on #39 Motion to Partially Redact Transcript by REACH Air Medical Services LLC. (Schramek, Adam) Modified text on 3/6/2023 (BD). |
| Filing 42 RESPONSE to Motion re #39 Opposed MOTION to Partially Redact Telephonic Preliminary Pretrial Conference #36 Transcript filed by Kaiser Foundation Health Plan Inc.. (Dodd, Christian) |
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Filing 41
ENDORSED ORDER granting #38 Defendant Kaiser Foundation Health Plan Inc.'s Unopposed Motion for Leave to File Reply Brief. Kaiser Foundation Health Plan Inc. may file a reply of no more than 7 pages no later than 3/10/2023. Signed by Judge Timothy J. Corrigan on 2/22/2023. (RMV)
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| Filing 40 NOTICE of Supplemental Authority in Support of #19 MOTION to Dismiss by C2C Innovative Solutions, Inc. (Giboney, Pierce) Modified text on 2/20/2023 (BD). |
| Filing 39 Opposed MOTION to Partially Redact Telephonic Preliminary Pretrial Conference #34 Transcript (electronic notification sent to Court Reporter Shannon Bishop) by REACH Air Medical Services LLC. (Attachments: #1 Affidavit)(Chang, Abraham) Modified on 2/10/2023 (BD). |
| Filing 38 Unopposed MOTION for Leave to File Reply Brief by Kaiser Foundation Health Plan Inc. (Dodd, Christian) (Modified on 2/8/2023, to edit text) (BGR). |
| Filing 37 RESPONSE in Opposition re #30 MOTION to Dismiss Complaint and to Strike Claim for Attorney's Fees filed by REACH Air Medical Services LLC. (Chang, Abraham) |
| Filing 36 NOTICE of intent to request redaction by Lanny Russell re #34 Transcript (Russell, Lanny) |
| Filing 35 NOTICE to counsel of filing of OFFICIAL TRANSCRIPT. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days. Any party needing a copy of the transcript to review for redaction purposes may purchase a copy from the court reporter or view the document at the clerk's office public terminal. Court Reporter: Shannon Bishop, RDR, CRR, CRC; dsmabishop@yahoo.com. (SB) |
| Filing 34 TRANSCRIPT of Telephonic Preliminary Pretrial Conference held on January 17, 2023 before Judge Timothy J. Corrigan. Court Reporter/Transcriber Shannon M. Bishop, RDR, CRR, CRC; dsmabishop@yahoo.com, Telephone number (904)549-1307. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER or purchased through the Court Reporter.. Redaction Request due 2/9/2023. Redacted Transcript Deadline set for 2/21/2023. Release of Transcript Restriction set for 4/19/2023. (SB) |
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Filing 33
ORDER setting a hearing on all pending motions for 5/16/2023 at 10:00 a.m. in Jacksonville Courtroom 10D before the undersigned; staying discovery. See Order for details. Signed by Judge Timothy J. Corrigan on 1/18/2023. (RMV)
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| Filing 32 Minute Entry. Telephonic Proceedings held before Judge Timothy J. Corrigan: PRELIMINARY PRETRIAL CONFERENCE held on 1/17/2023. Hearing on pending motions to be held on Tuesday, May 16, 2023 at 10:00 a.m. in Jacksonville Courtroom 10D. Order to enter. Court Reporter: Shannon Bishop (KKH) |
| Filing 31 NOTICE to the Courts to take judicial notice regarding #30 MOTION to Dismiss Complaint and to Strike Claim for Attorney's Fees by Kaiser Foundation Health Plan Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B)(Dodd, Christian) |
| Filing 30 MOTION to Dismiss Complaint and to Strike Claim for Attorney's Fees by Kaiser Foundation Health Plan Inc.. (Dodd, Christian) |
| Filing 29 REPLY to Response to Motion re #19 MOTION to Dismiss Plaintiff's Complaint and Motion to Strike Demand for Attorney's Fees filed by C2C Innovative Solutions, Inc.. (Giboney, Pierce) |
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Filing 28
ENDORSED ORDER granting #26 Unopposed Motion for leave to file reply to the extent that C2C may file a reply, limited to 7 pages. Because this case is set for a status conference on 1/17/2023 at which the motions to dismiss will be discussed (though not argued) and 1/16/2023 is a federal holiday, C2C is requested to file its reply brief not later than 1/13/2023. Signed by Judge Timothy J. Corrigan on 1/8/2023. (SRW)
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| Filing 27 CASE MANAGEMENT REPORT. (Russell, Lanny) |
| Filing 26 Unopposed MOTION for Leave to File Reply in Support of #19 Motion to Dismiss by C2C Innovative Solutions, Inc. (Giboney, Pierce) Modified text on 1/4/2023 (BD). |
| Filing 25 RESPONSE in Opposition re #19 MOTION to Dismiss Plaintiff's Complaint and Motion to Strike Demand for Attorney's Fees filed by REACH Air Medical Services LLC. (Chang, Abraham) |
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Filing 24
ENDORSED ORDER granting #23 Unopposed Motion for Leave to Exceed Page Limit: plaintiff's response to C2C's motion is limited to 30 pages. Signed by Judge Timothy J. Corrigan on 12/21/2022. (SRW)
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| Filing 23 MOTION to File Excess Pages in response to C2C's Motion to Dismiss and Motion to Strike by REACH Air Medical Services LLC. (Chang, Abraham) |
| Filing 22 Case Reassigned to Magistrate Judge Joel B. Toomey. New case number: 3:22-cv-1153-TJC-JBT. Magistrate Judge Laura Lothman Lambert no longer assigned to the case. (MDC) |
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Filing 21
ORDER Setting Hearing. Telephonic Preliminary Pretrial Conference set for 1/17/2023 at 4:00 PM before Judge Timothy J. Corrigan. See order for details. Signed by Judge Timothy J. Corrigan on 12/13/2022. (KKH)
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| Filing 20 CERTIFICATE of interested persons and corporate disclosure statement by C2C Innovative Solutions, Inc. identifying Corporate Parent C2C Innovative Solutions, Inc., Corporate Parent TMF Health Quality Institute, Other Affiliate Michael T Fackler, Other Affiliate Pierce N. Giboney, Other Affiliate Milam Howard Nicandri & Gillam, P.A. for C2C Innovative Solutions, Inc.. (Fackler, Michael) |
| Filing 19 MOTION to Dismiss Plaintiff's Complaint and MOTION to Strike Demand for Attorney's Fees by C2C Innovative Solutions, Inc. (Fackler, Michael) (Modified on 12/5/2022, to edit text) (BGR). |
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Filing 18
ENDORSED ORDER granting #17 Defendant Kaiser Foundation Health Plan, Inc.'s Unopposed Motion for Extension of Deadline to Respond to Plaintiff's Complaint. Defendant Kaiser Foundation Health Plan Inc. shall respond to the complaint on or before January 13, 2023. Signed by Magistrate Judge Laura Lothman Lambert on 11/29/2022. (KAS)
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| Filing 17 Unopposed MOTION For Extension of Deadline to Respond to #1 Complaint filed by Kaiser Foundation Health Plan Inc. (Dodd, Christian) Modified text and converted to a motion on 11/29/2022 (BD). |
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Filing 16
ORDER granting #13, #14, #15 Unopposed Motions for Special Admission of Moe Keshavarzi, Esq., John F. Burns, Esq., and Megan McKisson, Esq. Moe Keshavarzi, John F. Burns, and Megan McKisson are permitted to appear pro hac vice on behalf of the defendant Kaiser Foundation Health Plan Inc. Mr. Keshavarzi, Mr. Burns, and Ms. McKisson shall register with the Court's electronic case filing (ECF) system if they have not already done so. Signed by Magistrate Judge Laura Lothman Lambert on 11/28/2022. (MDC)
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| Filing 15 Unopposed MOTION for Megain McKisson to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-20236568 for $150 by Kaiser Foundation Health Plan Inc.. (Dodd, Christian) Motions referred to Magistrate Judge Laura Lothman Lambert. |
| Filing 14 Unopposed MOTION for John F. Burns to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-20236567 for $150 by Kaiser Foundation Health Plan Inc.. (Dodd, Christian) Motions referred to Magistrate Judge Laura Lothman Lambert. |
| Filing 13 MOTION for Moe Keshavarzi to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-20236565 for $150 by Kaiser Foundation Health Plan Inc.. (Dodd, Christian) Motions referred to Magistrate Judge Laura Lothman Lambert. |
| Filing 12 NOTICE to counsel Mohammad Keshavarzi, John F. Burns and Megan McKisson of Local Rule 2.01(c), Special Admission of Non-Resident Lawyer - File a Motion to Appear Pro Hac Vice. Co-counsel with filing rights may electronically file the motion on behalf of the non-resident lawyer or the motion may be filed on paper; Pay the Special Admission Fee; (Signed by Deputy Clerk). (BD) |
| Filing 11 CORPORATE Disclosure Statement by Kaiser Foundation Health Plan Inc.. (Dodd, Christian) |
| Filing 10 STIPULATION re #1 Complaint, Extending Time for Kaiser Foundation Health Plan Inc. to Respond to Complaint by Kaiser Foundation Health Plan Inc.. (Dodd, Christian) |
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Filing 9
ORDER granting #8 Motion for Special Admission. Adam T. Schramek, Esq., is permitted to appear pro hac vice on behalf of plaintiff. Mr. Schramek shall register with the Court's electronic case filing (ECF) system if he has not already done so. Signed by Magistrate Judge Laura Lothman Lambert on 11/2/2022. (KAS)
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| Filing 8 MOTION for Adam T. Schramek to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-20151818 for $150 by REACH Air Medical Services LLC. (Russell, Lanny) Motions referred to Magistrate Judge Laura Lothman Lambert. |
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Filing 7
ORDER granting #6 Motion for Special Admission. Abraham Chang is permitted to appear pro hac vice on behalf of the plaintiff REACH Air Medical Services LLC. Mr. Chang shall register with the Court's electronic case filing (ECF) system is he has not already done so. Signed by Magistrate Judge Laura Lothman Lambert on 11/1/2022. (MDC)
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| Filing 6 MOTION for Abraham Chang to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-20147510 for $150 by REACH Air Medical Services LLC. (Russell, Lanny) Motions referred to Magistrate Judge Laura Lothman Lambert. |
| Filing 5 NOTICE of Local Rule 3.02(a)(2), which requires the parties in every civil proceeding, except those described in subsection (d), to file a case management report (CMR) using the uniform form at www.flmd.uscourts.gov. The CMR must be filed (1) within forty days after any defendant appears in an action originating in this court, (2) within forty days after the docketing of an action removed or transferred to this court, or (3) within seventy days after service on the United States attorney in an action against the United States, its agencies or employees. Judges may have a special CMR form for certain types of cases. These forms can be found at www.flmd.uscourts.gov under the Forms tab for each judge. (Signed by Deputy Clerk). (KKH) |
| Filing 4 NOTICE to counsels Adam T. Schramek and Abraham Chang of Local Rule 2.01(c), Special Admission of Non-Resident Lawyer - File a Motion to Appear Pro Hac Vice. Co-counsel with filing rights may electronically file the motion on behalf of the non-resident lawyer or the motion may be filed on paper; Pay the Special Admission Fee; (Signed by Deputy Clerk). (BD) |
| Filing 3 SUMMONS issued as to Kaiser Foundation Health Plan Inc., REACH Air Medical Services LLC. (BD) |
| Filing 2 NEW CASE ASSIGNED to Judge Timothy J. Corrigan and Magistrate Judge Laura Lothman Lambert. New case number: 3:22-cv-1153-TJC-LLL. (SJB) |
| Filing 1 COMPLAINT against C2C Innovative Solutions, Inc., Kaiser Foundation Health Plan Inc. (Filing fee $402 receipt number AFLMDC-20133228) filed by REACH Air Medical Services LLC. (Attachments: #1 Civil Cover Sheet, #2 Proposed Summons Kaiser Foundation Health Plan Inc, #3 Proposed Summons C2C Innovative Solutions, Inc.)(Russell, Lanny) |
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