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

Filing 16

ORDER Granting 15 Stipulation for Extension of Time re 6 Motion to Dismiss (Second Request). Replies due by 7/31/2018. Signed by Chief Judge Gloria M. Navarro on 7/23/2018. (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]
[SECOND 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 record, 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. On July 17, 2018, the parties stipulated and agreed that the Surgery Center Parties’

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reply should be continued from July 17, 2018 to at least July 24, 2018, as a professional courtesy to

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the Surgery Center Parties’ counsel and further indicated that Dr. Canale was still considering the

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Surgery Center Parties’ request for an additional week extension of their reply deadline, to July 31,

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2018. (See ECF No. 14.)

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4. Following the Court’s approval of their Stipulation on July 17, 2018, Dr. Canale

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confirmed that he was agreeable to the Surgery Center Parties’ additional week-long extension (to

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give the Surgery Center Parties’ counsel adequate time to prepare the reply following a large

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document disclosure in an unrelated matter).

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5. Therefore, the parties now hereby stipulate and agree that the Surgery Center Parties’
reply should be further extended from July 24, 2018 to July 31, 2018.

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6. This is the second stipulation for an extension of time for the Surgery Center Parties

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

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to delay the proceedings.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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DATED this 20th day of July, 2018.

DATED this 20th 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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Attorneys for Defendants Sahara Outpatient
Surgery Center, Ltd. and Surgicare of Las
Vegas, Inc.

IT IS SO ORDERED.

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

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DATED this ___ day of July, 2018.

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UNITED STATES DISTRICT JUDGE
____________________________
Gloria M. Navarro, Chief Judge
United States District Court

DATED:
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