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.
DECLARATION OF ISAAC MITRANI IN SUPPORT OF DEFENDANTS’ UNOPPOSED MOTION TO CONTINUE TRIAL DATE
I, ISAAC MITRANI, declare under penalty of perjury pursuant to 28 U.S.C. § 1746 that:
1. I am an attorney and managing director of the law firm of Mitrani Rynor Adamsky Toland, P.A., with offices at 301 Godfrey Road, Penthouse, Miami Beach, Florida 33140, attorneys for Defendants US Stem Cell Clinic, LLC; US Stem Cell, Inc.; Dr. Kristin C. Comella (collectively, the “Defendants”). I am over the age of eighteen and understand the nature and obligations of a declaration made under the penalty of perjury. I have personal knowledge of the facts contained in this Declaration, and if called as a witness, I could and would testify competently under oath as to such facts. I submit this declaration in support of Defendants’ Motion to Continue the Trial Date.
2. I intend to serve as trial counsel for Defendants, along with Michael Blume (pro hac vice pending) and Mary M. Gardner of Venable LLP.
Case 0:18-cv-61047-UU Document 64-1 Entered on FLSD Docket 04/11/2019 Page 2 of 2
3. As I am admitted to the bar of the United States District Court for the Southern District o f Florida and have tried cases before the Southern District o f Florida for over thirty years, I intend to serve as an integral part ofthe Defendants' trial team.
4. I am unable to work on June 10, 2019, the first scheduled day of trial, due to religious observance o f the Jewish holiday o f Shavuot.
5. Moreover, I am unable to attend trial from June 14, 2019 to June 17, 2019, as I am scheduled to attend my son's graduate school graduation in California and will be traveling and attending graduation activities during that time period.
I declare under penalty ofperj that the foregoing is true and correct.
Dated: April 11, 2019
