Free Notice of Joinder - District Court of California - California

Case 3:07-cv-02408-DMS-LSP

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Filed 01/02/2008

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Robert F. Semmer (State Bar No. 102576) Cathleen G. Fitch (State Bar No. 95302) COUGHLAN, SEMMER & LIPMAN, LLP 501 West Broadway, Suite 400 San Diego, CA 92101 (619) 232-0800 (619) 232-0107 (Fax) Attorneys for SHC Management Corporation, a dissolved Georgia Corporation

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA DAVID J. CHAO, an individual, Plaintiff, vs. HEALTHSOUTH CORPORATION, a Delaware corporation; SHC SAN DIEGO, INC., a Georgia corporation; SHC MANAGEMENT COMPANY, a Georgia corporation; SURGICAL HEALTH CORPORATION, a Delaware corporation; HEALTHSOUTH SURGERY CENTERSWEST, INC., a Delaware corporation; SURGICAL CARE AFFILIATES, LLC a Delaware Limited Liability corporation; ARTHROSCOPIC & LASER SURGERY CENTER OF SAN DIEGO, L.P., and DOES 1 through 100, inclusively, Defendants. TO THE CLERK AND JUDGES OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA: PLEASE TAKE NOTICE that Defendant SHC MANAGEMENT CORPORATION, a dissolved Georgia corporation, and without waiving its lack of capacity to be sued, by and through its attorneys Coughlan, Semmer & Lipman, LLP, hereby joins in the Notice of Removal -1Case No. 3:07-CV-2408 DMS WMc Joinder of SHC Management Corporation in Notice of Removal

CASE NO. 3:07-CV-2408 DMS WMc JOINDER OF DEFENDANT SHC MANAGEMENT CORPORATION IN NOTICE OF REMOVAL OF CIVIL ACTION TO UNITED STATES DISTRICT COURT PURSUANT TO 28 U.S.C. § 1441(b)

Case 3:07-cv-02408-DMS-LSP

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of Civil Action of Defendant Surgical Care Affiliates, LLC, filed on December 26, 2007. DATED: January 2, 2008 Respectfully submitted, COUGHLAN, SEMMER & LIPMAN, LLP

By

s/ Cathleen G. Fitch Robert F. Semmer, Esq. Cathleen G. Fitch, Esq. Attorneys for SHC Management Corporation

@PFDesktop\::ODMA/PCDOCS/CSL/65391/1

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Case 3:07-cv-02408-DMS-LSP

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CERTIFICATE OF SERVICE

I, the undersigned, hereby certify: 1. I am over the age of 18 years and a resident of San Diego County, California; my business address is 501 W. Broadway, Suite 400, San Diego, California 92101; I am not a party to the above-entitled action; 2. On this date I caused the following document(s) to be filed and served electronically via the Court's CM/ECF System except as otherwise stated in paragraph #3 below: JOINDER OF DEFENDANT SHC MANAGEMENT CORPORATION IN NOTICE OF REMOVAL OF CIVIL ACTION TO UNITED STATES DISTRICT COURT PURSUANT TO 28 U.S.C. § 1441(b) 3. I caused the documents listed above to be served on the following party/parties by other means addressed to the last known address and delivered as follows: [ ] Each envelope was placed for deposit in the U.S. Mail according to the normal business practices observed at this office, with first class postage prepaid to: N/A I declare that I am a member of the Bar of this Court, and it was at my direction the above described service was made. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 2, 2008, California. s/ Cathleen G. Fitch

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