Valley Health System, LLC et al v. Travel Insurance Facilities, PLC et al

Filing 32

ORDER - Plaintiffs' motion to extend time (ECF No. 31 ) is granted. Plaintiffs shall have until September 25, 2022 to serve Defendant Travel Insurance Facilities, PLC. Signed by Magistrate Judge Daniel J. Albregts on 7/29/2022. (Copies have been distributed pursuant to the NEF - HKL)

1
2
3
4
5
6
7
8
9
10
11
12
13

JASON M. WILEY, ESQ.
Nevada Bar No. 09274
RYAN S. PETERSEN, ESQ.
Nevada Bar No. 10715
WILEY PETERSEN
1050 Indigo Drive, Suite 200B
Las Vegas, Nevada 89145
Telephone: [phone]
Facsimile: 702.553.3467
[e-mail]
[e-mail]
Timothy M. Hartley, Esq.
(PRO HAC VICE)
HARTLEY LAW OFFICES, PLC
12 Southeast Seventh Street, Suite 610
Fort Lauderdale, Florida 33301
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiffs Valley Health Systems, LLC
DVH Hospital Alliance, LLC and
Summerlin Hospital Medical Center, LLC
UNITED STATES DISTRICT COURT

14
15
16
17
18
19
20
21
22
23
24
25
26

DISTRICT OF NEVADA
VALLEY HEALTH SYSTEM, LLC, a Delaware
Limited Liability company, DVH HOSPITAL CASE NO.: 2:22-CV-00365-ART-DJA
ALLIANCE, LLC, a Delaware Limited Liability
company, and SUMMERLIN HOSPITAL
MEDICAL CENTER, LLC, a Delaware Limited PLAINTIFF’S LOCAL RULE IA 6-1.
Liability company,
MOTION FOR ENLARGEMENT OF
TIME TO EFFECTUATE SERVICE
Plaintiffs,
vs.
TRAVEL INSURANCE FACILITIES, PLC, a
Foreign
Corporation,
UNION
REISEVERSICHERUNG
AKTIENGESELLSCHAFT,
a
Foreign
Corporation,
Defendants.

27

COME NOW, Plaintiffs, Valley Health System, LLC, DVH Hospital Alliance, LLC, and

28

Summerlin Hospital Medical Center, LLC, (collectively, “Plaintiffs”), by and through their
1

1

undersigned counsel, and, pursuant to Local Rule 6-1 hereby move this Honorable Court for an

2

enlargement of time for an additional sixty (60) days through and including September 25, 2022

3

within which to effectuate service of the Summons, Complaint and Standing Order upon Defendant,

4

TRAVEL INSURANCE FACILITIES, PLC, a Foreign Corporation, and state as follows:

5

1.

Since the filing of the Complaint, the Plaintiff has attempted to obtain service of the

6

Summons, Complaint and Standing Order on Defendant, TRAVEL INSURANCE FACILITIES,

7

PLC, a Foreign Corporation (“TIF”), through the Hague Convention.

8

2.

The undersigned has been advised that due to processing delays in the United

9

Kingdom, there have been significant delays in obtaining service and receiving proof of service on

10

the Defendant. We expect that service will be completed soon but until then, we are requesting an

11

additional sixty (60) days to obtain service of the Summons, Complaint and Standing Order upon the

12

Defendant.

13

3.

While Fed.R.Civ.P. 4(m) requires service within 90 days after filing of a Complaint,

14

subdivision (m) does not apply to service in a foreign country under Rule 4(f) or 4(h)(2), the

15

provisions under which the Plaintiff is attempting to obtain service on the Defendants in this action.

16

4.

Nevertheless, in an abundance of caution and in the interests of judicial economy, the

17

Plaintiff requests an additional sixty (60) days to obtain service of the Summons, Complaint and

18

Standing Order upon the Defendant and respectfully requests this Honorable Court enter its Order

19

enlarging the time to effectuate service accordingly.

20

5.

This Motion is made in good faith and not for the purposes of harassment or delay.

21
22

///

23
24

///

25
26

///

27
28

///
2

1

WHEREFORE, for the foregoing reasons, Plaintiffs, Valley Health System, LLC, DVH

2

Hospital Alliance, LLC, and Summerlin Hospital Medical Center, LLC, respectfully request an

3

additional sixty (60) days through and including September 25, 2022, in which to effectuate service

4

of Summons and Complaint upon the Defendant, TIF as aforesaid and for such other and further relief

5

as the Court deems appropriate.

6

DATED this 27th day of July, 2022.

7

WILEY PETERSEN

8

/s/ Jason M. Wiley
______________________________
JASON M. WILEY, ESQ.
Nevada Bar No. 09274
RYAN S. PETERSEN, ESQ.
Nevada Bar No. 10715
WILEY PETERSEN
1050 Indigo Drive, Suite 200B
Las Vegas, Nevada 89145
Telephone: [phone]
Facsimile: 702.553.3467
[e-mail]
[e-mail]

9
10
11
12
13
14
15

Timothy M. Hartley, Esq.
(PRO HAC VICE)
HARTLEY LAW OFFICES, PLC
12 Southeast Seventh Street,
Suite 610
Fort Lauderdale, Florida 33301
Telephone: [phone]
Fax: [phone]
[e-mail]

16
17
18
19
20

Attorneys for Plaintiffs Valley Health
Systems, LLc, DVH Hospital
Alliance, LLC and Summerlin
Hospital Medical Center, LLC

21
22
23
24
25

IT IS THEREFORE ORDERED that Plaintiffs' motion to extend time (ECF No. 31) is
granted.
IT IS FURTHER ORDERED that Plaintiffs shall have until September 25, 2022 to
serve Defendant Travel Insurance Facilities, PLC.

26
____________________________________
DANIEL J. ALBREGTS
UNITED STATES MAGISTRATE JUDGE

27
28
3

DATED: July 29, 2022

CERTIFICATE OF SERVICE

1
2

I hereby certify that I am an employee of Wiley Petersen, and that on the 27th day of July,

3

2022, I caused to be served a true and correct copy of the foregoing PLAINTIFF’S LOCAL RULE

4

IA 6-1. MOTION FOR ENLARGEMENT OF TIME TO EFFECTUATE SERVICE in the

5

following manner:

6

(ELECTRONIC SERVICE) Pursuant to Rule 5-4 of the Local Rules of Civil Practice of the

7

United States District Court for the District of Nevada, the above-referenced document was

8

electronically filed on the date hereof and served through the Notice of Electronic Filing automatically

9

generated by that Court’s facilities.

10

(UNITED STATES MAIL) By depositing a copy of the above-referenced document for

11

mailing in the Unites States Mail, first-class postage prepaid, at Las Vegas, Nevada, to the parties

12

listed below at their last-known mailing addresses, on the date above written.

13
14
15
16
17
18
19
20

(ELECTRONIC E-MAIL)
Pat Lundvall (NSBN 3761)
Daniel Aquino (NSBN 12682)
McDONALD CARANO LLP
2300 West Sahara Avenue, Suite 1200
Las Vegas, Nevada 89102
Telephone: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants Travel Insurance Facilities, PLC
and Union Reiseversicherung Aktiengesellschaft

21
/s/ Timothy M. Hartley, Esq.

22
23
24

_____________________________________
HARTLEY LAW OFFICES, PLC

25
26
27
28
4