Omni Healthcare Inc. v. North Brevard County Hospital District
6:22-cv-00696
M.D. Fla.Jun 4, 2025Background
- Plaintiffs, the United States and State of Florida ex rel. Dr. Craig Deligdish, brought a suit involving North Brevard County Hospital District and Halifax Hospital Medical Center.
- Plaintiff moved to stay discovery while motions to dismiss were pending, or, alternatively, requested a 12-month extension of all deadlines.
- The district judge had already issued a Report and Recommendation concerning the motions to dismiss, finding some claims should proceed and others dismissed.
- The case followed a case management and scheduling order (CMSO), outlining deadlines and discovery procedures.
- The current motion was challenged on the grounds of lack of good cause to stay or extend deadlines, emphasizing court preference for expeditious case management.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Stay of discovery pending motion to dismiss | Discovery should be stayed or extended until after the motion to dismiss is resolved to avoid unnecessary expense. | Case should not be delayed; motions to dismiss not wholly dispositive of the case. | Stay denied; discovery proceeds. |
| Extension of all deadlines by 12+ months | Extension necessary due to case complexity and pending motions. | No good cause; delays not justified by diligence or law. | Extension denied; no good cause shown. |
| Application of good cause standard | Plaintiff did not explicitly address or satisfy stringent diligence requirements. | Defendant argued lack of diligence and reference to CMSO requirements. | Motion denied; lack of diligence fatal to extension. |
| Tolling of deadlines | Implied that motion to dismiss should toll deadlines. | Argued deadlines remain in force unless altered by order. | Deadlines were not tolled. |
Key Cases Cited
- Feldman v. Flood, 176 F.R.D. 651 (M.D. Fla. 1997) (discovery stays generally disfavored; balancing harm from delay against possible elimination of need for discovery)
- Sosa v. Airprint Sys., Inc., 133 F.3d 1417 (11th Cir. 1998) (good cause to modify scheduling order requires diligence)
- Johnson v. Mammoth Recreations, Inc., 975 F.2d 604 (9th Cir. 1992) (lack of diligence ends the good cause inquiry)
- Chudasama v. Mazda Motor Corp., 123 F.3d 1353 (11th Cir. 1997) (discovery should not be stayed merely upon filing a motion to dismiss)