US Stem Cell Inc (USRM)

[a1tellem]

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FT. LAUDERDALE DIVISION
CASE NO.: 18-CV-61047
UNITED STATES OF AMERICA, Plaintiff,
v.
US STEM CELL CLINIC, LLC, a Florida limited liability company,
US STEM CELL, INC., a Florida profit corporation, and
KRISTIN C. COMELLA and THEODORE GRADEL, individuals,
Defendants.
DEFENDANTS’ UNOPPOSED REQUEST FOR HEARING
Pursuant to Local Rule 7.1(b)(2), Defendants US Stem Cell Clinic, LLC, US Stem Cell, Inc., and individual Dr. Kristin C. Comella request the opportunity to present oral argument on each party’s Motion for Summary Judgment (Dkt. No. 41 and 42). Upon submission of the parties’ motions for summary judgment, oppositions thereto, and replies in further support, Defendants appreciate that the parties and the Court are likely to benefit from an in-person hearing regarding the complex legal and scientific issues presented by the parties in the motions. Defendants believe that an allotment of one hour will be sufficient time for this hearing. Plaintiff has represented that it believes the motions can be decided on the written record, but does not oppose the relief requested.
DATED: April 10, 2019 Respectfully Submitted,
/s/ Isaac J. Mitrani Isaac J. Mitrani
Florida Bar No. 348538

Case 0:18-cv-61047-UU
Document 61
Entered on FLSD Docket 04/10/2019
Page 2 of 3
Loren H. Cohen
Florida Bar No. 303879
MITRANI, RYNOR,
ADAMSKY & TOLAND, P.A.
301 Arthur Godfrey Road, Penthouse Miami Beach, FL 33140
Tel.: [phone]
Fax: [phone] [e-mail] [e-mail] [e-mail] [e-mail] [e-mail]
Todd A. Harrison (admitted pro hac vice) Todd H. Halpern (admitted pro hac vice) Stephen R. Freeland (admitted pro hac vice) Mary M. Gardner (admitted pro hac vice) Venable LLP
600 Massachusetts Avenue NW Washington, DC 20001
Attorneys for Defendants US Stem Cell Clinic, LLC, US Stem Cell, Inc., and Kristin C. Comella
LOCAL RULE 7/1 CERTIFICATE OF GOOD FAITH CONFERENCE
The undersigned attorney, counsel for Defendants, hereby certifies that she has conferred with Mr. Roger Gural, Esq., counsel for Plaintiff, and is authorized to represent that Plaintiff believes the motions can be decided on the written record, but does not oppose the relief requested.
/s/ Mary M. Gardner

Case 0:18-cv-61047-UU Document 61 Entered on FLSD Docket 04/10/2019 Page 3 of 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 10, 2019, a true and correct copy of the foregoing Defendants’ Unopposed Request for Hearing was filed with the Clerk of the Court via CM/ECF and the CM/ECF system will send a notice of electronic filing to all counsel and parties of record listed on the Service List Below.
/s/ Isaac J. Mitrani
Isaac J. Mitrani
Florida Bar No. 348538
MITRANI, RYNOR,
ADAMSKY & TOLAND, P.A.
301 Arthur Godfrey Road, Penthouse Miami Beach, FL 33140
Tel.: [phone]
Fax: [phone] [e-mail] [e-mail] [e-mail] [e-mail]
Attorneys for Defendants US Stem Cell Clinic, LLC, US Stem Cell, Inc., Kristin C. Comella and Theodore Gradel