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

Filing 25

ORDER Granting 24 Stipulation for Extension of Time re 1 Petition for Removal (First Request). Lance Hickman answer due 9/28/2018. Signed by Magistrate Judge Cam Ferenbach on 9/24/2018. (Copies have been distributed pursuant to the NEF - MR)

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DAVID J. MERRILL
Nevada Bar No. 6060
DAVID J. MERRILL, P.C.
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145
Telephone: [phone]
E-mail: [e-mail]
Attorney for Defendant Lance Hickman

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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,

2:18-CV-01020-GMN-(VCF)

Plaintiff,

Stipulation and Order to Extend Time to
File Response to the Complaint

vs.

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(First Request)

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,
Defendants.

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In accordance with LR 7-1(a), the plaintiff, Paul B. Canale, M.D., and defendant Lance Hickman, stipulate as follows:
1.

On April 17, 2018, Dr. Canale filed a complaint in the Eighth Judicial

District Court. (ECF No. 1-2). Defendants Sahara Outpatient Surgery Center, Ltd.
and Surgicare of Las Vegas, Inc. removed the action to this Court on June 5, 2018.
(ECF No. 1.) Dr. Canale served Hickman with a copy of the summons and complaint
on September 1, 2018. (ECF No. 23). Under Fed. R. Civ. P. 12(1)(a)(1) and
6(a)(1)(C), Hickman has up to and including September 24, 2018, to file a response
to the complaint.

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2.

Because counsel for Hickman was out-of-state, he requested, and Dr.

Canale’s counsel agreed, to a brief extension until Friday, September 28, 2018.

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3.

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the complaint.

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5.

Accordingly, the parties stipulate that Hickman shall have up to and

including September 28, 2018, to file a response to the complaint.

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The parties have agreed to this extension for good cause and not solely

for the purpose of delay.

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This is the first stipulation for an extension of time to file a response to

Dated this 24th day of September 2018.
Erickson & Whitaker PC

David J. Merrill, P.C.

By:

By:

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/s/ Brian C. Whitaker
Brian C. Whitaker
1349 Galleria Drive, Suite 200
Henderson, Nevada 89014
[phone]
Attorney for Plaintiff

/s/ David J. Merrill
David J. Merrill
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145
[phone]
Attorney for Defendant Lance Hickman

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It is so ordered:

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United States Magistrate
Judge
Dated: September 24, 2018

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