Scott Freeman, M.D., v. Stephen Hurst, et al.

Filing 164

ORDER Granting 161 Stipulation for Extension of Time. Savant Addiction Medicine, LLC and Savant HWP Holdings, Inc. answer due 2/9/2024. Signed by Magistrate Judge Maximiliano D. Couvillier, III on 2/6/2024. (Copies have been distributed pursuant to the NEF - JQC)

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1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 99 BRODY R. WIGHT, ESQ. Nevada Bar No. 13615 JAMES H.S. LEVINE (pro hoc viche) TROUTMAN PEPPER HAMILTON SANDERS LLP 8985 S. Eastern Ave., Ste 200 Las Vegas, NV 89123 (Nevada Office) Tel: (470) 832-5586 Fax: (404) 962-6800 brody.wight@troutman.com TROUTMAN PEPPER HAMILTON SANDERS LLP 600 Peachtree St. NE # 3000 Atlanta, GA 30308 (Corporate Office) Attorneys for Savant Addiction Medicine LLC and Savant HWP Holdings, LLC. 10 10 UNITED STATES DISTRICT COURT 11 11 DISTRICT OF NEVADA 12 12 13 13 14 14 SCOTT FREEMAN, M.D., as TRUSTEE FOR THE SCOTT MITCHELL FREEMAN REVOCABLE LIVING TRUST, dated March 10, 2012, for itself as assignee of FERDINAND BELGA; 15 15 16 16 17 17 18 18 19 19 20 20 21 21 24 24 Consolidated with: 2:22-cv-01903-JCM-BNW Plaintiffs, vs. STEPHEN HURST; SUNRAY ASSET MANAGEMENT, INC.; NICO FORTE; CERUVIA LIFESCIENCES f/k/a CH-TAC; CAREY TURNBULL; RUSSELL BURBANK, as liquidating trustee for nominal defendants SAVANT ADDICTION MEDICINE, LLC and SAVANT HWP HOLDINGS, LLC; DOE INDIVIDUALS 1 through 20; and ROE CORPORATIONS 1 through 20, 22 22 23 23 Case No.: 2:22-cv-01433-RFB-MDC STIPULATION AND PROPOSED ORDER TO EXTEND THE DEADLINE FOR DEFENDANTS SAVANT ADDICTION MEDICINE LLC AND SAVANT HWP HOLDINGS, LLC TO RESPOND TO THE SECOND AMENDED COMPLAINT Defendants. and 25 25 SAVANT ADDICTION MEDICINE, LLC; SAVANT HWP HOLDINGS, LLC; and SAVANT HWP, INC., 26 26 Nominal Defendants. 27 27 28 PAGE 1 129296299 1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 Plaintiff SCOTT FREEMAN, M.D., as TRUSTEE FOR THE SCOTT MITCHELL FREEMAN REVOCABLE LIVING TRUST, dated March 10, 2012, for itself as assignee of FERDINAND BELGA (Plaintiff) and Defendants SAVANT ADDICTION MEDICINE, LLC and SAVANT HWP HOLDINGS, LLC (collectively, Defendants), by their attorneys, hereby submit this Stipulation to extend the deadline for Defendants to file the response to the Second Amended Complaint. On December 6, 2023, Plaintiff filed a Second Amended Complaint in this action consisting of 1,271 paragraphs and 116 exhibits (ECF Nos. 141 through 145–50). Due to the length of the Second 8 Amended Complaint, the parties agreed that all defendants would have until February 2, 2024, to file 99 responses to the Second Amended Complaint, and the stipulation was adopted by the Court in the Second 10 10 Amended Joint Discovery Plan and Scheduling order. ECF No. 136. 11 11 Throughout the month of January, Defendants’ lead counsel suffered from a severe case of the flu 12 12 and pneumonia, which resulted in a multi-day hospitalization. These illnesses substantially impacted 13 13 counsel’s ability to perform legal work. 14 14 As a courtesy to counsel as a result of the above-described illness, the parties agree that 15 15 Defendants’ response to the Second Amended Complaint should be extended to February 9, 2024. The 16 16 parties stipulate to this extension in good faith and not to harass or cause undue delay. 17 17 The parties’ specific stipulations are as follows: 18 18 1. The deadline for Defendants SAVANT ADDICTION MEDICINE, LLC and SAVANT 19 19 HWP HOLDINGS, LLC to file a response to the Second Amended Complaint, currently set for February 20 20 2, 2024, should be extended to February 9, 2024. 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 PAGE 2 129296299 1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 99 10 DATED this 2nd day of February 2024 DATED this 2nd day of February 2024 LEWIS ROCA ROTHGERBER CHRISTIE TROUTMAN PEPPER HAMILTON SANDERS LLP /s/ J. Christopher Jorgensen Daniel F. Polsenberg, Nevada Bar No. 2376 J. Christopher Jorgensen Nevada Bar No. 5382 Abraham G. Smith Nevada Bar No. 13250 3993 Howard Hughes Pkwy., Ste. 600 Las Vegas, NV 89169 /s/ Brody R. Wight Brody R. Wight Nevada Bar No. 13615 James H.S. Levine (pro hoc vice) 8985 S. Eastern Ave., Ste. 200, Las Vegas, NV 89123 (Nevada Office) 600 Peachtree St. NE # 3000, Atlanta, GA 30308 Attorneys for Savant Addiction Medicine LLC and Savant HWP Holdings, LLC. Attorneys for Plaintiff 10 11 11 12 12 13 13 14 14 15 15 ORDER IT IS HEREBY ORDERED the deadline for Defendants SAVANT ADDICTION MEDICINE, LLC and SAVANT HWP HOLDINGS, LLC to file a response to the Second Amended Complaint, currently set for February 2, 2024, should be extended to February 9, 2024. 16 16 17 17 18 18 JUDGE, UNITED STATES DISTRICT COURT Dated: 2/6/2024 19 19 20 20 Respectfully submitted by: 21 21 TROUTMAN PEPPER HAMILTON SANDERS LLP 22 22 /s/ Brody R. Wight Brody R. Wight Nevada Bar No. 13615 James H.S. Levine (pro hoc viche) 8985 S. Eastern Ave., Ste. 200, Las Vegas, NV 89123 (Nevada Office) 600 Peachtree St. NE # 3000, Atlanta, GA 30308 23 23 24 24 25 25 26 26 27 27 Attorneys for Savant Addiction Medicine LLC and Savant HWP Holdings, LLC. 28 PAGE 3 129296299 1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 2nd day of February 2024, I caused to be served a true and correct copy of the foregoing STIPULATION AND PROPOSED ORDER TO EXTEND THE DEADLINE FOR DEFENDANTS SAVANT ADDICTION MEDICINE LLC AND SAVANT HWP HOLDINGS, LLC TO RESPOND TO THE SECOND AMENDED COMPLAINT, in the following manner: ☒ (ELECTRONIC SERVICE) Pursuant to FRCP 5(b), the above referenced document was 8 electronically filed on the date hereof with the Clerk of the Court for the United States District Court by 99 using the Court's CM/ECF system and served through the Court's Notice of electronic filing system 10 10 11 11 automatically generated to those parties registered on the Court's Master E-Service List. ☒ (UNITED STATES MAIL) By depositing a copy of the above-referenced document for 12 12 mailing in the United States Mail, first-class postage prepaid, to the parties listed below at their last-known 13 13 mailing addresses, on the date above written. 14 14 15 15 16 16 David S. Kupetz Sulmeyer Kupetz 333 South Hope Street Thirty-Fifth Floor Los Angeles, CA 90071-1406 Rory S. Miller Locke Lord LLP 300 S. Grand Ave. Suite 2600 Los Angeles, CA 90071 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 26 26 William C Mullen Locke Lord LLP 300 S. Grand Avenue Suite 2600 Los Angeles, CA 90071 ☐ (PERSONAL SERVICE) By causing to be personally delivered a copy of the above-referenced document to the person(s) listed below: N/A ☐ (EMAIL) By emailing a true and correct copy of the above-referenced document to the person(s) listed below: N/A I declare that I am employed in the office of a member of the bar of this Court at whose discretion the service was made. /s/ Carla Llarena An employee of TROUTMAN PEPPER HAMILTON SANDERS, LLP 27 27 28 PAGE 4 129296299

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