Canale v. Sahara Outpatient Surgery Center, Ltd. et al

Filing 14

ORDER Granting 13 Stipulation for Extension of Time re 6 Motion to Dismiss (First Request). Replies due by 7/24/2018. Signed by Chief Judge Gloria M. Navarro on 7/17/2018. (Copies have been distributed pursuant to the NEF - MR)

JOSHUA M. DICKEY
Nevada Bar No. 6621
ANDREA M. CHAMPION
Nevada Bar No. 13461
BAILEYKENNEDY
8984 Spanish Ridge Avenue
Las Vegas, Nevada 89148-1302
Telephone: [phone]
Facsimile: 702.562.8821
[e-mail]
[e-mail]

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Attorneys for Defendants Sahara Outpatient
Surgery Center, Ltd.; and Surgicare of Las
Vegas, Inc.

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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PAUL B. CANALE, M.D., an individual and
Alabama resident,

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Plaintiff,

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v.

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SAHARA OUTPATIENT SURGERY CENTER,
LTD., a Nevada limited partnership;
SURGICARE OF LAS VEGAS, INC., a Nevada
corporation; LANCE HICKMAN, an individual
and Tennessee resident; DOES I through X; ROE
CORPORATIONS I through X, inclusive,

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Case No. 2:18-cv-01020-GMN-VCF
STIPULATION AND ORDER TO
EXTEND DEADLINE FOR SAHARA
OUTPATIENT SURGERY CENTER,
LTD. AND SURGICARE OF LAS
VEGAS, INC.’S REPLY IN SUPPORT
OF THE MOTION TO DISMISS [ECF
NO. 6]
[FIRST REQUEST]

Defendants.

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Plaintiff Paul B. Canale, M.D. (“Plaintiff”), together with Defendants Sahara Outpatient

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Surgery Center, Ltd. and Surgicare of Las Vegas, Inc. (collectively, the “Surgery Center Parties”),

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by and through their respective attorneys of records, stipulate and agree as follows:

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1. On June 19, 2018, the Surgery Center Parties filed and served their Motion to Dismiss
[ECF No. 6].

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2. Dr. Canale filed his Opposition to the Motion to Dismiss on July 10, 2018 [ECF No.
12].1

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Dr. Canale’s deadline within which to file his Opposition was extended by the parties’ agreement and approved
by the Court on June 30, 2018. (See ECF No. 9.)

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3. The Surgery Center Parties’ reply in support of the Motion to Dismiss is currently due
on July 17, 2018.

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4. The parties stipulate and agree that the date for the Surgery Center Parties’ reply

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deadline shall be continued from July 17, 2018 to July 24, 2018 as a professional courtesy to the

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Surgery Center Parties’ counsel.2

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5. This is the first stipulation for an extension of time for the Surgery Center Parties to

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file their reply in support of the Motion to Dismiss. This stipulation is made in good faith and not to

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delay the proceedings.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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DATED this 17th day of July, 2018.

DATED this 17th day of July, 2018.

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ERICKSON & WHITAKER PC

BAILEYKENNEDY

By:

By:

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/s/ Brian C. Whitaker
BRIAN C. WHITAKER
1349 Galleria Drive
Suite 200
Henderson, NV 89014

Attorneys for Plaintiff Paul B. Canale, M.D.

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/s/ Andrea M. Champion
JOSHUA M. DICKEY
ANDREA M. CHAMPION
8984 Spanish Ridge Avenue
Las Vegas, NV 89148

Attorneys for Defendants Sahara Outpatient
Surgery Center, Ltd. and Surgicare of Las
Vegas, Inc.

IT IS SO ORDERED.

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DATED this 17 day of July, 2018. UNITED STATES DISTRICT JUDGE
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___________________________
Gloria M. Navarro, Chief Judge
United States District Court

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DATED:

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The Surgery Center Parties originally requested a two-week extension of their reply deadline and understand, at
the time of this filing, that Dr. Canale is still considering the Surgery Center Parties’ request for an additional week. If
parties subsequently agree to extend the Surgery Center Parties’ reply deadline to July 31, 2018, they will file a second
stipulation and order reflecting the same.

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