Bernstein & Poisson, LLC v. Standmore et al

Filing 5

ORDER Granting 4 Stipulation for Extension of Time to Extend United States' Answering Deadline re 1 Petition for Removal. United States Department of Treasury answer due 8/5/2024. Signed by Magistrate Judge Elayna J. Youchah on 7/2/2024. (Copies have been distributed pursuant to the NEF - ALZ)

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1 JASON M. FRIERSON United States Attorney 2 District of Nevada Nevada Bar No. 7709 3 LINDSAY A. AGER Assistant United States Attorney 4 Nevada Bar No. 11985 501 Las Vegas Blvd. So., Suite 1100 5 Las Vegas, Nevada 89101 (702) 388-6336 6 Lindsay.Ager@usdoj.gov 7 Attorneys for the United States 8 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 9 10 Bernstein & Poisson, a Nevada Corporation, 11 12 v. Case No. 2:24-cv-01177-APG-EJY Plaintiff, Cynthia Standmore, an individual; JSF Stipulation to Extend United States’ 13 Incorporated DBA Chiropractic Physicians of Answering Deadline Las Vegas; Cameron Medical, Inc.; Coppel (First Request) 14 Medical Enterprise LLC DBA Nevada Comprehensive Pain Centers; United States 15 Department of the Treasury; State of Nevada, Department of Health Human Services; 16 Golden Pear Funding II, LLC, a New York Limited Liability Company; Preferred Capital 17 Funding – Nevada, LLC; DOES 1 through 100; ROE Corporations l0l through 200, 18 Defendants. 19 20 This is an interpleader case that the United States removed from Nevada state court 21 on June 27, 2024. Following the United States’ removal, counsel for plaintiff Bernstein & 22 Poisson and counsel for the United States held a telephonic meet-and-confer conference 23 regarding various issues in this case. High Stakes Injury Law (formerly Bernstein & Poisson) 24 is in the process of communicating with several defendants regarding the amounts of their 25 liens. Counsel for the United States identified the appropriate point of contact at the United 26 States Department of Health and Human Services and its delegate agency, the Centers for 27 Medicare and Medicaid Services, and is in the process of gathering the facts necessary to 28 answer or otherwise respond to the complaint. 1 Under Federal Rule of Civil Procedure 81(c)(2)(C), the United States’ current 2 deadline to answer or otherwise respond to the complaint is July 4, 2024, which is 3 Independence Day. Because Independence Day is a legal holiday as defined by Rule 4 6(a)(6)(A), under Rule 6(a)(1)(C), the deadline runs until July 5, 2024, which is the next day 5 that is not a legal holiday. 6 The parties stipulate that the United States’ deadline to answer or otherwise respond 7 to plaintiff’s complaint will be extended by one month, or from July 5, 2024, to August 5, 8 2024. The purpose of the stipulation is to allow the United States adequate time to 9 investigate the facts before answering or otherwise responding to the complaint. Also, the 10 additional time will allow the parties an opportunity to continue their meet-and-confer 11 efforts regarding the various’ parties’ interests in this case, which should streamline the 12 litigation. This is the first stipulation to extend time for the United States to answer or 13 otherwise respond to the complaint. 14 IT IS SO STIPULATED. 15 Dated: July 2, 2024 Dated: July 2, 2024 AMBER N. KING High Stakes Injury Law JASON M. FRIERSON United States Attorney /s/ Amber N. King Attorney for Plaintiff /s/Lindsay Ager LINDSAY AGER Assistant United States Attorney 16 17 18 19 20 21 22 IT IS SO ORDERED. 23 24 25 _________________________________ United States Magistrate Judge 26 Dated: July 2, 2024 27 28 2

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