@robf270 I would include language in the motion that states what deadlines the judge gave them to submit their response, and then you to reply to their response. Make it as complete as possible so that the judge doesn't have to shuffle through papers to get the information.
Is it possible for you to draft a quick Kentucky rule-compliant affidavit to attest to the date you received the motion opposition response? I honestly don't know if it's necessary, but you could also include a statement in the affidavit that the envelope was USPS postmarked July 16, 2018. A true and correct copy of the postmarked envelope is attached as Exhibit A. Or something to that effect.
Agreed Order Law and Legal Definition
An Agreed Order refers to a written agreement submitted by the parties to a case resolving the issues between them. Once the agreed order is approved by the court and entered in its minutes, it becomes the order or decree of the court with all of the force and effect that any order would have after a full hearing prior to adjudication.
Until brought to the attention of the Trial Judge, an "agreed order" is no order at all, but merely an agreement of the parties. It has no significance as a judicial act until a judicial act (decision) gives it significance.[Zeitlin v. Zeitlin, 544 S.W.2d 103, 106 (Tenn. Ct. App. 1976)]
I am not a lawyer. It appears to me that you need to include language whether the other party denied consent or not.
It's your call. It could potentially be an FDCPA violation if they insist they can charge it but it's not in the agreement, so a paper trail wouldn't be a bad idea.
What did the medical provider have to say about the interest?