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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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: [phone]
Fax: [phone]
[e-mail]
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.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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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;

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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,

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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

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SAVANT ADDICTION MEDICINE, LLC;
SAVANT HWP HOLDINGS, LLC; and
SAVANT HWP, INC.,

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Nominal Defendants.

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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

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Amended Complaint, the parties agreed that all defendants would have until February 2, 2024, to file

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responses to the Second Amended Complaint, and the stipulation was adopted by the Court in the Second

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Amended Joint Discovery Plan and Scheduling order. ECF No. 136.

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Throughout the month of January, Defendants’ lead counsel suffered from a severe case of the flu

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and pneumonia, which resulted in a multi-day hospitalization. These illnesses substantially impacted

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counsel’s ability to perform legal work.

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As a courtesy to counsel as a result of the above-described illness, the parties agree that

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Defendants’ response to the Second Amended Complaint should be extended to February 9, 2024. The

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parties stipulate to this extension in good faith and not to harass or cause undue delay.

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The parties’ specific stipulations are as follows:

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1.

The deadline for Defendants SAVANT ADDICTION MEDICINE, LLC and SAVANT

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HWP HOLDINGS, LLC to file a response to the Second Amended Complaint, currently set for February

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2, 2024, should be extended to February 9, 2024.

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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

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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.

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JUDGE, UNITED STATES DISTRICT COURT
Dated: 2/6/2024

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Respectfully submitted by:

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TROUTMAN PEPPER HAMILTON SANDERS LLP

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/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

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Attorneys for Savant Addiction Medicine LLC
and Savant HWP Holdings, LLC.

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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

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electronically filed on the date hereof with the Clerk of the Court for the United States District Court by

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using the Court's CM/ECF system and served through the Court's Notice of electronic filing system

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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

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mailing in the United States Mail, first-class postage prepaid, to the parties listed below at their last-known

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mailing addresses, on the date above written.

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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

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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

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