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Full title: Motion to Continue Hearing Filed by Lauren M. Nash on behalf of United States Department of Health and Human Services, Medicare, Creditor (RE: [2061] Clerks Notice of ZoomGov Instructions Regarding Scheduled Hearing) (Attachments: # (1) Proposed Order) (Nash, Lauren)

Document posted on Oct 14, 2021 in the bankruptcy, 4 pages and 0 tables.

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The United States of America, by and through its attorneys, on behalf of the U.S. Department of Health and Human Services (the “United States”) hereby submits this second motion to continue the hearing on its Amended Application for Allowance and Payment of the Administrative Expense Claim for Medicare Overpayments in the above-captioned case.In his Statement, the Trustee indicated that he needed to confirm the allegations set forth in the USA Administrative claim, including the overpayments of $67,597.72 alleged by HHS, and to better understand the relief requested by the USA. The Trustee asked the Court to schedule a hearing on the USA Administrative Claim “so that relief will not simply enter as part of the Court’s contested matter procedure, and the Trustee will have an opportunity to perform due diligence in connection with a hearing.”Following the issuance of the Notice of Hearing, the undersigned counsel had discussions with the Chapter 7 Trustee along with Regional Counsel for HHS with a view towards satisfying the Trustee’s concerns regarding HHS’s administrative claim.Email: Lauren.Nash@usdoj.gov 1 Undersigned counsel has not served the Notice of Hearing (ECF No. 2061) and will refrain from doing so in light of this motion for continuance.

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UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT ___________________________________________ In re: : : Chapter 7 THE ROSEGARDEN HEALTH AND : REHABILITATION CENTER, LLC, : Case No. 18-30623 (AMN) : BRIDGEPORT HEALTHCARE CENTER : Joint Administration INC., : : Debtors. : October 15, 2021 ___________________________________________ SECOND MOTION TO CONTINUE HEARING ON AMENDED APPLICATION FOR ADMINISTRATIVE EXPENSES (ECF NO. 2051) The United States of America, by and through its attorneys, on behalf of the U.S. Department of Health and Human Services (the “United States”) hereby submits this second motion to continue the hearing on its Amended Application for Allowance and Payment of the Administrative Expense Claim for Medicare Overpayments in the above-captioned case. In support of this motion, undersigned counsel for the United States respectfully submits the following: 1. On August 23, 2021, the United States filed an Amended Request for Allowance and Payment of Administrative Expense Claims on behalf of the U.S. Department of Health and Human Services (“HHS”). See ECF No. 2051 (“USA Administrative Claim”). 2. On September 7, 2021, the Chapter 7 Trustee filed a Statement in Response to the USA Administrative Claim. See ECF No. 2056. In his Statement, the Trustee indicated that he needed to confirm the allegations set forth in the USA Administrative claim, including the overpayments of $67,597.72 alleged by HHS, and to

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better understand the relief requested by the USA. Id. at 2. The Trustee asked the Court to schedule a hearing on the USA Administrative Claim “so that relief will not simply enter as part of the Court’s contested matter procedure, and the Trustee will have an opportunity to perform due diligence in connection with a hearing.” Id. 3. On September 8, 2021, the Court issued a Notice of Hearing with respect to the USA Administrative Claim. See ECF No. 2057. The hearing was scheduled for October 6, 2021. Id. Following the issuance of the Notice of Hearing, the undersigned counsel had discussions with the Chapter 7 Trustee along with Regional Counsel for HHS with a view towards satisfying the Trustee’s concerns regarding HHS’s administrative claim. 4. Because those discussions were ongoing, undersigned counsel sought and obtained a continuance of the October 6, 2021 hearing. See ECF No. 2059. The continued hearing is scheduled for October 20, 2021. See ECF No. 2061. 5. The undersigned counsel requests a second continuance of the hearing, scheduled for October 20, 2021. Discussions between the undesigned counsel and the Trustee are still ongoing, and the additional time may result in a resolution of the Trustee’s concerns and the need for a hearing. 6. The Chapter 7 Trustee has given his consent to this second continuance sought by the United States. 2

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WHEREFORE, the United States requests that the hearing scheduled for October 20, 2021 be continued to a future date convenient to the Court.1 Respectfully submitted, LEONARD C BOYLE ACTING UNITED STATES ATTORNEY /s/ Lauren M. Nash ___________________________________ LAUREN M. NASH, ct01705 ASSISTANT UNITED STATES ATTORNEY 157 CHURCH STREET NEW HAVEN, CT 06510 PH: (203) 821-3700 / FAX: (203) 773-5373 Email: Lauren.Nash@usdoj.gov 1 Undersigned counsel has not served the Notice of Hearing (ECF No. 2061) and will refrain from doing so in light of this motion for continuance. 3

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UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT ___________________________________________ In re: : : Chapter 7 THE ROSEGARDEN HEALTH AND : REHABILITATION CENTER, LLC, : Case No. 18-30623 (AMN) : BRIDGEPORT HEALTHCARE CENTER : Joint Administration INC., : : Debtors. : October 15, 2021 ___________________________________________ CERTIFICATION OF SERVICE I hereby certify that on October 15, 2021, a copy of the foregoing SECOND MOTION TO CONTINUE HEARING ON AMENDED APPLICATION FOR ADMINISTRATIVE EXPENSES (ECF NO. 2051) was filed electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court’s electronic filing system. Parties may access this filing through the Court’s CM/ECF System. /s/ Lauren M. Nash ___________________________________ LAUREN M. NASH, ct01705 ASSISTANT UNITED STATES ATTORNEY 4

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