GIDDENS et al v. TIFT REGIONAL HEALTH SYSTEM INC et al

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Case 7:25-cv-00163-WLS Document 5
Filed 11/20/25 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA VALDOSTA DIVISION
JOAN GIDDENS and MARVIN GIDDENS
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Plaintiffs,
Case No .: 7:25-cv-00163-WLS
V.
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TIFT REGIONAL HEALTH
SYSTEM, INC. d/b/a TIFT
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REGIONAL MEDICAL CENTER,
JAMES SCOTT, M.D., and SMITH AND NEPHEW, INC.
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Defendants.
STIPULATION OF EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFFS' COMPLAINT
Pursuant to Fed. R. Civ. P. 6(b) and Local Rule 6.1, Plaintiffs Joan Giddens and Marvin Giddens and Defendant Smith and Nephew, Inc. (the "Parties") hereby stipulate that the time within which Defendant Smith and Nephew, Inc. shall answer or otherwise respond to Plaintiffs' Complaint through a motion to dismiss is extended from November 18, 2025, through and including December 15, 2025.
By signing and executing this "Stipulation" the Plaintiffs are not consenting, nor agreeing, to the removal of the above-styled case to the United States District Court for the Middle District of Georgia, nor do the Plaintiffs consent, or agree, that
AUTHENTICATED U.S. GOVERNMENT INFORMATION
GPO
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Case 7:25-cv-00163-WLS Document 5 Filed 11/20/25
Page 2 of 3
the United States District Court for the Middle District of Georgia has jurisdiction in this matter.
If Defendant Smith and Nephew, Inc. files a motion to dismiss Plaintiffs' Complaint, then the Parties stipulate to the following briefing schedule consistent with deadlines imposed by Local Rules 7.2 and 7.3:
1. Defendant Smith and Nephew, Inc.'s Motion to Dismiss shall be filed by December 15, 2025;
2. Plaintiffs' Opposition to Defendant Smith and Nephew, Inc.'s Motion to Dismiss shall be filed by January 5, 2026;
3. Defendant Smith and Nephew, Inc.'s reply brief shall be filed by January 19, 2026.
Respectfully submitted this 18th of November, 2025.
TUCKER & BROWNING LAW,
P.C.
/s/ Alan David Tucker
/s/ Avery G. Carter
Elizabeth C. Helm
Georgia Bar No. 289930
kate.helm@nelsonmullins.com
Avery G. Carter
avery.carter@nelsonmullins.com
Georgia Bar No. 789576
201 17th Street, NW, Suite 1700
Atlanta, GA 30363
(404) 322-6000
(404) 322-6050 (fax)
Counsel for Defendant Smith and Nephew, Inc.
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W. Louis Sands, Sr. Judge United States District Court
NELSON MULLINS RILEY & SCARBOROUGH LLP
Alan David Tucker
(Signed with express permission)
alan@tuckerandbrowning.com
Georgia Bar No. 717559
4 St. Andrews Court
Brunswick, Georgia 31520
(912) 267-7123
(912) 289-2448
Counsel for Plaintiffs
SO ORDERED this. 19th day of. november .2025
W. Loni Aanca

Case 7:25-cv-00163-WLS Document 5
Filed 11/20/25 Page 3 of 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November 18, 2025, I electronically filed the foregoing with the Clerk of the Court by using the CM/ECF which will automatically send notification of such filing to all counsel of record who are registered to receive electronic notification.
I further certify that I have this day served the within and foregoing upon all pro-se parties via United States mail with adequate postage affixed, addressed as follows:
James Scott, M.D. 2227 U.S. Hwy 41N Tifton, GA 31794
Pro Se Defendant
This 18th day of November, 2025.
/s/ Avery G. Carter Avery G. Carter Georgia Bar No. 789576
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